NORONT RESOURCES LTD. EAGLE S NEST PROJECT

Transcription

1 NORONT RESOURCES LTD. EAGLE S NEST PROJECT TERMS OF REFERENCE

2

3 NORONT RESOURCES LTD. EAGLE S NEST PROJECT TERMS OF REFERENCE (REF. NO. ) TABLE OF CONTENTS PAGE SECTION INTRODUCTION INTRODUCTION... 1 SECTION IDENTIFICATION OF THE PROPONENT... 2 SECTION APPROACH TO CONDUCTING THE EA INDICATION OF HOW THE EA WILL BE PREPARED REPORTING... 3 SECTION PURPOSE OF THE UNDERTAKING PURPOSE OF THE ENVIRONMENTAL ASSESSMENT ENVIRONMENTAL ASSESSMENT REQUIREMENTS Starting the EA Process Provincial EA Requirements Federal EA Requirements and Process Process of a Coordinated EA FAR NORTH PLANNING ACT SECTION DESCRIPTION OF AND RATIONALE FOR THE PROJECT PROJECT LOCATION PROJECT RATIONALE PROJECT LIFE CYCLE Project Phases Construction Phase Operations Phase Closure and Post-Closure Phase PROJECT DESCRIPTION SUMMARY Mine Development Mine Design Ore Processing Concentrate Handling and Storage Explosives Production Power Supply Water Supply Waste Management Access Roads i of vi

4 Airstrip Support Facilities SECTION DESCRIPTION OF AND RATIONALE FOR ALTERNATIVES INTRODUCTION SELECTION OF ALTERNATIVES ALTERNATIVES TO ALTERNATIVE METHODS OF CARRYING OUT THE PROJECT SECTION DESCRIPTION OF THE EXISTING ENVIRONMENT AND POTENTIAL EFFECTS OF THE PROJECT PROJECT DESCRIPTION IDENTIFICATION OF STUDY AREAS General Study Area Caribou Study Area GENERAL SITE INFORMATION PHYSIOGRAPHY, GEOLOGY AND GEOCHEMISTRY CLIMATE AND METEOROLOGY HYDROLOGY HYDROGEOLOGY WATER QUALITY BIOLOGY Terrestrial Environment Aquatic Environment SOCIO-ECONOMIC AND CULTURAL Regional Land Use Aboriginal Communities Cultural Resources BASELINE STUDY PROGRAMS BASELINE CHARACTERIZATION TOOLS Surface Water Quality and Quantity Groundwater Quality and Quantity Terrestrial Baseline Studies Aquatic Baseline Studies Physiography, Geology and Geochemistry Climate and Meteorology Socio-economic Baselines Studies Cultural Resources POTENTIAL EFFECTS OF THE PROJECT Mine Development and Operation Water Management Systems Power Generation Transfer Facility Development and Operation Access Road Corridor Development and Operation Airstrip ii of vi

5 Waste Management Systems Potential Socio-Economic Effects of Mine Operation CUMULATIVE ENVIRONMENTAL EFFECTS SECTION ASSESSMENT AND EVALUATION OF THE ALTERNATIVES EVALUATION METHODS Net Effect Analysis Comparative Evaluation - Reasoned Argument IMPACT ASSESSMENT Natural Environment Socio-economic/Cultural Environment SECTION POTENTIAL MITIGATION MEASURES SECTION COMMITMENTS AND MONITORING MONITORING PLANS Environmental Management Plan Social Management Plan SECTION CONSULTATION PLAN AND CONSULTATION TO DATE CONSULTATION PLAN FOR THE ENVIRONMENTAL ASSESSMENT Introduction Objectives CONSULTATION TO DATE PRE-EA CONSULTATION ACTIVITIES Public Municipal Provincial and Federal Government Aboriginal Engagement Participation of Métis Communities Issues and Concerns SECTION FLEXIBILITY TO ACCOMMODATE NEW CIRCUMSTANCES SECTION OTHER APPROVALS REQUIRED SECTION CERTIFICATION TABLES Table 6.1 Table 6.2 Table 8.1 Table 11.1 Table 11.2 Table 11.3 Preliminary List of Alternatives To Preliminary List of Alternative Methods Preliminary List of Evaluation Criteria, Indicators and Potential Data Sources Preliminary Issue Categories and Subjects Summary of Aboriginal Engagement Meetings Preliminary Summary of Issues and Concerns iii of vi

6 Table 13.1 Table 13.2 Preliminary List of Permits, Licenses and Approvals Preliminary List of Policies, Guidelines, Criteria and Standards FIGURES Figure 4.1 Figure 4.2 Figure 4.3 Figure 5.1 Figure 7.1 Figure 7.2 Figure 7.3 Figure 7.4 Figure 7.5 Provincial Individual EA Process CEA Agency Comprehensive Study Process Coordinated EA Process Project Location Map Local Study Area - Eagle s Nest Mine Site Local Study Area - Webequie Junction Local Study Area - Savant Lake Local Study Area Access Corridor & Pipeline Regional Study Area APPENDICES Appendix A Appendix B Consultation Plan Caribou Information and Analysis Requirements for the Eagle s Nest Project iv of vi

7 Glossary of Terms and Acronyms Alternative Alternative methods Alternatives to ARD/ML ATK CEEA CEA Agency CEPA Concentrate COSEWIC DFO Do Nothing Alternative EA EC EIS EMPs EMS Include both alternatives to and alternative methods to a proposed undertaking Alternative methods of carrying out a proposed undertaking are different ways of doing the same activity Alternatives to the proposed undertaking are functionally different ways of approaching and dealing with a problem or opportunity that has been identified Acid rock drainage/metal leaching Aboriginal Traditional Knowledge Canadian Environmental Assessment Act Canadian Environmental Assessment Agency Canadian Environmental Protection Act Ore concentrate is the product generated by the milling process which removes the waste rock and concentrates the target metal component (i.e. nickel and copper) Committee on the Status of Endangered Wildlife in Canada Fisheries and Oceans Canada An alternative that is typically included in the evaluation of alternatives that identifies the implications of doing nothing to address the problem or opportunity Environmental assessment Environment Canada Environmental impact statement Environmental management plans Environmental management system The Ontario Environmental Assessment Act defines environment to mean: Environment EPA HADD Km kv MMER MNR MOE-EAB MNDM Air, land or water; Plant and animal life, including human life; The social, economic and cultural conditions that influence the life of humans or a community; Any building, structure, machine or other device or thing made by humans; Any solid, liquid, gas, odour, heat, sound, vibration, or radiation resulting directly or indirectly from human activities; or, Any part or combination of the foregoing and the interrelationships between any two or more of them. Environmental Protection Act Harmful, alteration, disruption or destruction of fish habitat Kilometres Kilovolt Metal Mining Effluent Regulations Ministry of Natural Resources Ontario Ministry of Environment Environmental Approvals Branch Ministry of Northern Development and Mines v of vi

8 MPMO NPAG NWPA OEAA PAG PM Project Proponent QA/QC SARA Supporting Documentation TIA ToR UTM Undertaking VEC Major Project Management Office Non-potentially acid-generating Navigable Waters Protection Act Ontario Environmental Assessment Act Potentially acid-generating Particulate matter Eagle s Nest Project Noront Resources Ltd. Quality assurance/quality control Species at Risk Act Documentation that is submitted to the ministry of environment, in addition to the terms of reference, which provides further information on issues discussed in the terms of reference. Information contained in the supporting documentation should support the proponent s request that the terms of reference be approved by providing justification for the choices made and details of processes or methodologies to be used Tailings impoundment area Terms of reference Universal Transverse Mercator An enterprise, activity or a proposal, plan, or program that a proponent initiates or proposes to initiate Valued Ecosystem Component vi of vi

9 NORONT RESOURCES LTD. EAGLE S NEST PROJECT TERMS OF REFERENCE (REF. NO. ) SECTION INTRODUCTION 1.1 INTRODUCTION The purpose of this report is to present the Terms of Reference (ToR) for the Noront Eagle s Nest Project environmental assessment, in compliance with provincial laws, regulations, and guidelines applicable to the development of mining projects in Ontario. The Terms of Reference have been prepared to show how Noront intends to meet the requirements of Ontario s Environmental Assessment Act (OEAA) during the preparation of the Environmental Assessment (EA). The ToR is a work plan which becomes the framework for the preparation and review of the EA. It will be made available to the public and will be submitted to the Ministry of the Environment for review and a decision on whether to allow the Project to proceed. The Project is also subject to a Federal EA and must meet the requirements of the Canadian Environmental Assessment Act. In order to meet these requirements the EA must also meet the requirements of the federal EIS guidelines which were accepted in January Canada and Ontario entered into an agreement in 2004 (Canada-Ontario Agreement on Environmental Assessment Cooperation (2004)). The federal and provincial governments have indicated a willingness to follow the coordinated EA process for this project. The EIS guidelines and the ToR will be used in coordination to produce a body of documentation that meets the requirements of both. 1 of 63

10 SECTION IDENTIFICATION OF THE PROPONENT Noront Resources Ltd. (Noront) is a Canadian mining company focused on exploration and development in the Ring of Fire region of northern Ontario. Noront is a publicly traded company on the Toronto Stock Exchange (TSX Venture: NOT). The Company is the sole proponent of the Eagle s Nest Project (Project) and holds a 100 % interest in all of the underlying claims. Noront s corporate contact information is: Noront Resources Ltd. 105 Adelaide Street West Suite 1100 Toronto, Ontario Canada M5H 1P9 Telephone: Facsimile: Website: The primary contacts for the Project are: Mr. Paul Semple, P.Eng. Chief Operating Officer Noront Resources Ltd. Paul.Semple@norontresources.com Mr. Mark Baker, P.Eng. Project Manager Noront Resources Ltd. Mark.Baker@norontresources.com 2 of 63

11 SECTION APPROACH TO CONDUCTING THE EA 3.1 INDICATION OF HOW THE EA WILL BE PREPARED The EA for the Project will be prepared in accordance with the ToR as approved by the Minister of the Environment and in accordance with the requirements of the Ontario Environmental Assessment Act (OEAA), R.S.O. 1990, Chapter E. 18. Planning for the Project has been underway for some time and the potential alternatives that Noront wishes to evaluate are constrained by the nature of the Project and the studies completed to date. The alternatives that will not be carried forward to the EA include; the location of the Project, mining method (underground vs. open-pit), north-south road option and alternatives related to power supply. Noront is focusing the assessment of alternatives so the EA will be prepared in accordance with Sections 6(2)(a) and 6.1(3) of the OEAA. These requirements will be addressed through completion of: (a) a description of the purpose of the undertaking; (b) a description of and a statement of the rationale for, (i) the undertaking, (ii) the alternative methods of carrying out the undertaking, and (iii) the alternatives to the undertaking; (c) a description of, (i) the environment that will be affected or that might reasonably be expected to be affected, directly or indirectly, (ii) the effects that will be caused or that might reasonably be expected to be caused to the environment, and (iii) the actions necessary or that may reasonably be expected to be necessary to prevent, change, mitigate or remedy the effects upon or the effects that might reasonably be expected upon the environment, by the undertaking, the alternative methods of carrying out the undertaking and the alternatives to the undertaking; (d) an evaluation of the advantages and disadvantages to the environment of the undertaking, the alternative methods of carrying out the undertaking and the alternatives to the undertaking; and (e) a description of any consultation about the undertaking by the proponent and the results of the consultation The objectives of this ToR are to describe the approach and the methods that will be used to meet these requirements. Rationale as to why the aforementioned alternatives are not being carried forward into the EA is provided within the supporting documentation accompanying the ToR. 3.2 REPORTING An EA report will be prepared to address all requirements outlined in the ToR and be consistent with the purpose of the OEAA and the public interest. The EA will provide details regarding the rationale for the selected Project approach and will be written to meet all provincial and federal requirements. 3 of 63

12 The EA will include the information requirements set out in the OEAA, as outlined in Section 3.1, and include the requirements outlined in the EIS Guidelines. Separate technical appendices will be provided for each of the component studies. The components to be addressed through Technical Support Documents (TSDs) include: Physiography and geology Air quality and noise Climate and meteorology Hydrology Hydrogeology Groundwater and surface water quality and geochemistry Terrestrial biology Aquatic biology Socio-economic, cultural resources and recreational and tourism use of Otoskwin-Attawapiskat Provincial Park The TSDs will include detailed descriptions of the existing environment as determined from the baseline studies, details of any modeling and data assessments undertaken, and the details on impact assessment methods, results and conclusions. 4 of 63

13 SECTION PURPOSE OF THE UNDERTAKING The overall purpose of the Project is to develop a multi-metal underground mine to produce and supply a concentrate to smelter customers containing nickel, copper, platinum and palladium minerals. The undertaking involves the construction, operation and closure, including remediation, of an underground mining facility and associated infrastructure at the mine site, along the access corridor, and at supporting facilities south of Webequie and near Savant Lake. The high-grade nickel-copper-precious metals deposit contains approximately 11 million tonnes of resources, which will provide for an 11 year mine life at the planned extraction rate of 2,960 tonnes per day (t/d). Several other components will be developed in conjunction with mine site development. Supporting infrastructure will include the following: Webequie Junction Concentrate Transfer Facility Transmission line All season road Winter road Airstrip Waste management facilities Concentrate pipeline Savant Lake Concentrate Transfer Facility Webequie Junction will serve as the central hub for concentrate shipping and also house the power generation plant for the mine site. Concentrate will be transported from the mine site via an approximately 90 km long pipeline and will be dewatered at Webequie Junction and loaded onto haul trucks. Webequie Junction was selected as the site for diesel-fuel power generation in order to minimize the risks associated with shipping fuel along the winter road corridor and reduce the need for storing large quantities of fuel on-site. A 25 MW diesel-fuelled power generation plant will provide power to Webequie Junction and the mine site. Power will be transmitted to the mine site through a 69 kv overhead transmission line. The all-season road will facilitate the movement of supplies and fuel to, and the shipment of concentrate out of, Webequie Junction. The all season road provides an efficient cost-effective means to ship concentrate to Savant Lake. An airstrip has also been included as a component of the Project. The airstrip will facilitate the movement of personnel and supplies to and from the mine site. It should be noted that the airstrip has existing OEAA coverage by a third party. However, because the airstrip is important to the Project it is being included as a component. Noront will not rely on the third party as they may decide to not proceed with the airstrip or significant changes may be made to the current proposal. Waste management facilities will be located at Webequie Junction and at the mine site. The waste facility located at the mine site will consist of an incinerator and a handling and sorting area. All wastes not fit to 5 of 63

14 be incinerated will be transported off site to a certified landfill. Mine site waste materials will be transported along the winter and all season roads to a certified landfill. The waste management facility located at Webequie Junction will not include an incinerator as all wastes produced at the Webequie Junction will be shipped off site in containers to a certified landfill. All waste management facilities will be fenced off to prevent nuisance animals including wolves and bears from accessing potential food sources. Concentrate will be transferred through the pipeline from the mine site to Webequie Junction during all seasons. Concentrate will be shipped via truck from the Junction to Savant Lake where it will be off-loaded and transferred into rail cars. Once loaded into rail cars, the concentrate will be shipped to an existing smelter for further processing. 4.1 PURPOSE OF THE ENVIRONMENTAL ASSESSMENT An environmental assessment (EA) is the primary means of assessing the potential environmental impacts the Project will have on the existing environment. The environment, as defined by the Ontario Environmental Assessment Act (OEAA), encompasses: Air, land or water Plant and animal life, including human life, the social, economic and cultural conditions that influence the life of humans or a community Any building, structure, machine or other device or thing made by humans Any solid, liquid, gas, odour, heat, sound, vibration, or radiation resulting directly or indirectly from human activities Any part or combination of the foregoing and the interrelationships between any two or more of them An EA ensures that Noront will present mitigation and management strategies, monitoring plans, and considers all options that may improve the Project s design and reduce the potential for adverse environmental impacts. This will allow Noront to assess potential environmental effects of the proposed undertaking before any decisions are made to proceed. This is accomplished through a comparative evaluation of alternatives. An environmental assessment also allows for consultation with potentially affected communities, government agencies and the general public to identify issues and concerns that will be considered during the planning of the Project and in the preparation of the EA. The EA will also provide an objective evaluation of the proposed undertaking of the Project and the potential impacts, advantages and disadvantages so that the Ontario Minister of the Environment can make a decision on whether or not the Project should be allowed to proceed. The EA process is governed by the (OEAA) and the Canadian Environmental Assessment Act. The requirements and process of undertaking a provincial EA are administered by the Ontario Ministry of the Environment (MOE). The federal EA process is discussed in Section of 63

15 The specific objectives of the EA for the Project are to: Describe the baseline environmental and socio-economic conditions, against which potential impacts will be assessed Describe the Project activities and identify where these may interact with the environment Develop assessment criteria and identify appropriate indicators of potential impacts Describe the environmental and socio-economic and cultural effects that may be generated by the Project during the construction, operations, closure and post closure phases Assess the advantages, disadvantages, and impacts of different alternatives to the Project Assess the impacts of different alternative methods of carrying out the Project Describe the criteria selection and decision making process in the selection of the preferred alternatives Propose environmental and social impact management plans to describe impact avoidance, mitigation and/or reclamation such that impacts are mitigated and benefits are enhanced during each stage of the Project Include in the environmental and social management plans monitoring programs to verify that measures taken to manage impacts and benefits are achieving identified targets Describe roles and responsibilities for managing and reporting on the Project s environmental and social performance Ensure the involvement of interested and affected parties in each of the above activities so that environmental and social management plans address and incorporate their issues and concerns Ensure the involvement of government agencies in the EA process to help to develop a project that can be approved, and ensure that the management plans address the requirements of the OEAA Assess the preferred alternatives in detail to determine residual effects after impact management measures have been applied Discuss the advantages and disadvantages of the undertaking 4.2 ENVIRONMENTAL ASSESSMENT REQUIREMENTS Starting the EA Process Prior to the preparation of the ToR, Noront discussed the Eagle s Nest Project with potentially affected First Nations and with provincial ministries (MOE, MNDM, MNR) and federal departments (CEA Agency, MPMO) in order to develop a robust Project Description. As the formal EA process gets underway, Noront expects that other provincial and federal ministries will continue to supply comments and suggest improvements to the Project. Similarly, Noront looks forward to receiving further comments from First Nations, Métis, ENGOs and the general public. The issuance of the ToR represents the first formal step in the provincial EA process for the Project. The ToR has been prepared in cooperation with the Aboriginal groups, provincial and federal governments and the public. The ToR is being submitted to the MOE for review and, if deemed sufficient by the MOE, will be forwarded to the Minister for approval. 7 of 63

16 Noront has presented one set of viable options in the ToR for each of the Project components; however, they do not necessarily represent the preferred or final design or scope of the Project. Details of the Project may change based on the results of ongoing studies, stakeholder discussions, and engagement activities. A range of alternatives has been identified for further evaluation, and these are detailed in Section 6. The EA will play a crucial part in the development of the final Project, through the consideration and assessment of alternatives as well as input received from various stakeholders. In July 2011 Noront submitted a Project Description to the federal government to initiate the EA process under the CEAA, and to the provincial government for information purposes. The Project Description meets the requirements of the federal Major Projects Management Office (MPMO) Guide to Preparing a Project Description for a Major Resource Project (December 2008) and was designed to follow the Ontario Ministry of Northern Development and Mines (MNDM) Project Definition Template for Advanced Exploration and Mine Development Projects. There are several EA and permitting authorizations which are required to develop a mine and related infrastructure in Ontario. While there are no specific provincial EA requirements for a mining development in Ontario, many of the individual Project elements trigger EA requirements. If the Project components change, the EA and permitting triggers may also change. There are specific federal EA requirements for mining development, and these are dealt with under CEAA. The process of permitting a mine in Ontario s Far North is also subject to the Far North Act, Under the Far North Act, subject to certain exceptions, development activities in the Far North may not take place until there is an approved community based Land Use Plan for the area. The proposed mine site, and much of the proposed integrated transportation system, falls within the Far North and as such will be subject to the provisions of the Far North Act. The Far North Act enables a community based land use planning process led by First Nations working jointly with Ontario. The result is the identification, within the community based Land Use Plans, of areas to be set aside for protection and areas suitable for sustainable economic development opportunities. Plans will establish land use designations and permitted uses for planning areas identified by First Nations. Community based Land Use Plans require joint approval by First Nations and the Ontario Ministry of Natural Resources. The Far North Act is discussed further in Section Provincial EA Requirements In Ontario, environmental assessment is an important planning and decision making process which has its authority in the OEAA. The OEAA provides for the protection, conservation, and wise management of Ontario s environment. In Ontario, projects may be subject to an Individual environmental assessment, or to a Class environmental assessments for classes of projects that are carried out routinely, and have predictable and mitigable environmental effects. 8 of 63

17 While there are no requirements in Ontario for a provincial individual EA for the proposed mining project as a whole, there are components of the project which will trigger either provincial Individual EAs or Class EAs, including: The proposed construction of a 25 MW diesel-fuelled power generation plant The proposed construction of a 225 km all-season road The Disposition of Rights to Crown Resources for Project development occurring on Crown Land The construction of power transmission lines The proposed power generation facility at Webequie Junction would be subject to an Individual EA, and the aforementioned Class EAs could be elevated to an Individual EA by the Minister due to unforeseen conditions or significant concerns being raised. In such a situation the review process would need to be restarted. Because of the number of provincial Class EAs required, and the need for an Individual EA for the power generation plant at Webequie Junction, Noront has voluntarily entered into a written agreement under Section of the OEAA to have the OEAA apply to the whole Project. Noront also believes that it will be easier to coordinate a single provincial EA, instead of several Class EAs, with the federal comprehensive study required for the Project. A number of Provincial approvals are also required for the Project. These approvals require the participation of the Ministry of Northern Development and Mines (MNDM), the Ministry of the Environment (MOE), the Ministry of Natural Resources (MNR), and the Ministry of Labour (MOL). This proposed ToR has been prepared following the Code of Practice: Preparing and Reviewing Terms of Reference for Environmental Assessments in Ontario (2009). The Provincial individual EA process and timelines are outlined in Figure 4.1. A ToR should lay out a clear assessment process and workplan for the proposed undertaking, including the: Identification of the purpose of the study or undertaking Description and rationale for the undertaking Description and rationale for a range of alternatives to be assessed Description of the environment and potential effects Assessment and evaluation of the alternatives, including identification of criteria, indicators and an evaluation method Consultation with potentially affected communities, governments and the public Selection of a preferred alternative to the undertaking and alternative methods The assessment of residual effects and the identification of potential mitigation measures should only take place after a range of alternatives have been evaluated to select a preferred undertaking. 9 of 63

18 4.2.3 Federal EA Requirements and Process Concurrent with the provincial EA, there is a federal EA process which is governed by the CEAA. The requirements and process of undertaking an EA are governed by the Canadian Environmental Assessment Agency (CEA Agency). The process used by CEA Agency is an environmental review that describes the natural and socio-economic environment that could be potentially affected by the Project. It also describes ways of protecting the environment. Under section 5 of the CEAA an environmental assessment is required because Natural Resources Canada may take action in relation to paragraph 7(1)(a) of the Explosives Act. The following permits and authorizations are not confirmed but may also be required: Fisheries and Oceans Canada may take action in relation to subsection 35(2) of the Fisheries Act Transport Canada may take action in relation to section 5 of the Navigable Waters Protection Act Health Canada, Environment Canada, and Aboriginal Affairs and Northern Development Canada have indicated that they possess expert information that could be useful to the environmental assessment. The Major Projects Management Office is also engaged in this Project as it is considered a Major Resource Project under the Major Resource Project Regulatory Improvement Initiative. The CEA Agency has determined that the Project as proposed by the Proponent is described in the following sections of the Comprehensive Study List Regulations under the Act: 10. The proposed construction, decommissioning or abandonment of a facility for the extraction of m 3 /a or more of ground water or an expansion of such a facility that would result in an increase in production capacity of more than 35 per cent; 30 (c) The proposed construction or decommissioning of an all-season runway with a length of m or more. The principal steps in the CEAA process typically include: Preparation of a Project Description for review by potentially involved federal authorities Pre-consultation with federal and provincial authorities, and also with members of the general public and First Nations that could potentially be affected by the Project Determination of the level of review by CEA Agency, whether screening, Comprehensive Study Report, mediation or Panel Development by of the Environmental Impact Statement (EIS) Guidelines by the CEA Agency to define those aspects of the Project that should be included in the EA, the focus and boundaries of the EA, stakeholders in the CEAA process (affected and interested parties, including government agencies, First Nations, and members of the general public, possibly 10 of 63

19 including non-governmental organizations - NGOs), consultation needs, and the extent of co-ordination with provincial regulatory requirements Consultation by Noront with provincial government agencies, affected First Nations, and potentially members of the general public and interest groups on the scope of the EA Preparation of a Comprehensive Study EA (CSEA) Review of the CSEA and related materials by federal and provincial regulators, local First Nations, and interested stakeholders Response by Noront to comments received from government agencies, First Nations and other stakeholders Preparation of a draft Comprehensive Study Report (CSR) taking into consideration comments on the CSEA from First Nations and other stakeholders Preparation of a final CSR Publication of the final CSR for the mandatory public review period Ministerial decision on the CSR and the adequacy of the proponent s obligations under the CEAA process While the CEAA process is underway, Noront may make submissions to the federal government on required federal authorizations, approvals and licenses for the Project. However, this will be done with the understanding that any such authorizations, approvals and licenses would not be fully reviewed or granted until after the CEAA process has been completed. The Project has been accepted for a federal Comprehensive Study. As required by the CEAA, the CEA Agency has prepared Guidelines for the Environmental Impact Statement to be prepared by Noront. The EIS Guidelines have been reviewed by the public and have been posted on the CEA Agency`s Canadian Environmental Assessment Registry (CEAR) website. Figure 4.2 outlines the steps and timelines in the Comprehensive Study Process Process of a Coordinated EA The steps in an EA required for the MOE and for the CEA Agency are somewhat different. Hence, a coordinated approach must integrate the requirements of both federal and provincial legislation. Canada and Ontario entered into an agreement in 2004 (Canada-Ontario Agreement on Environmental Assessment Cooperation (2004)). The two levels of government have indicated a willingness to follow the coordinated EA process for this Project, and with Noront, will agree on the approach to coordinating the EA to produce one body of documentation. Therefore, the EA document will address the requirements of both the provincial ToR and the federal EIS Guidelines. The coordinated EA process is summarized in the following five steps and is illustrated on Figure 4.3: Pre-EA Planning, including, signing of the voluntary agreement, development of the ToR and the EIS Guidelines 11 of 63

20 EA commencement Environmental baseline studies and preparation of the EIS/EA Report EA decision Monitoring and follow-up On August 3, 2011 the CEA Agency determined the Project Description to be acceptable and initiated the 90-day pre-environmental planning period. Noront entered into a written agreement under Section of the Ontario Environmental Assessment Act (OEAA) on September 9, Pre-EA activities have been discussed in multiple meetings with federal and provincial agencies and Noront. The EA commencement phase will include the development and approval of the ToR and the EIS guidance document. The ToR defines the provincial requirements and explains how Noront will undertake baseline studies and evaluate alternatives, while the EIS Guidelines identify the federal government s information requirements for the EA report. The EIS guidelines were finalized and posted in January Baseline environmental studies will be completed and Noront will prepare and submit the EA report to meet the needs of the provincial ToR and the federal EIS guidelines. The report will then be subject to federal, provincial and public review. Following the review period, the federal and provincial Ministers will provide a decision on the EA. Follow-up will confirm that significant adverse effects do not occur and any effects are as predicted. Following the approval of the EA, the follow-up program will be finalized. 4.3 FAR NORTH PLANNING ACT In addition to the federal and provincial environmental assessment acts, development in the Far North is governed by the Far North Act, Components of the Project, including the mine, Webequie Junction, all-season road, winter road, transmission line, and concentrate pipeline will be subject to the provisions of the Far North Act. The purpose of the Far North Act is to provide for community based land use planning in the Far North that: Sets out a joint planning process between the First Nations and Ontario Supports the environmental, social, and economic objectives for land use planning for the peoples of Ontario Is done in a manner that is consistent with the recognition and affirmation of existing Aboriginal and treaty rights in Section 35 of the Constitution Act, 1982, including the duty to consult Community based land use plans will establish land use designations and permitted uses for planning areas identified by the First Nations. Land use plans will require joint approval by First Nations and the Ontario Ministry of Natural Resources. 12 of 63

21 The Objectives of the Far North Act include: Ensuring a significant role for First Nations in planning The protection of areas of cultural value, and the protection of ecological systems by including at least 225,000 km 2 of the Far North in an interconnected network of protected areas designated in community based land use plans The maintenance of biological diversity, ecological processes and ecological functions, including the storage and sequestration of carbon in the Far North Enabling sustainable economic development that benefits the First Nations Under Section 12 of the Far North Act, the following activities are prohibited where community based land use plans do not exist: Opening a mine in the prescribed circumstances Commercial timber harvest Oil and gas exploration and production Constructing or expanding an electrical generation facility that uses wind or water as a source and any other infrastructure that is associated with it Constructing or expanding electrical transmission and distribution systems and transmission and distribution lines in accordance with the definitions of transmission system, transmit and distribute in the Electricity Act, 1998, and any other infrastructure that is associated with them, including all weather transportation infrastructure Construction or expanding any infrastructure that is prescribed Any other land use or activity that is prescribed Currently, there are no approved community based land use plans established within the Project`s areas of proposed development. First Nations and the government of Ontario are currently in the early stages of the planning process. 13 of 63

22 SECTION DESCRIPTION OF AND RATIONALE FOR THE PROJECT The project description provided in this ToR represents a Base Case or preliminary description of the Project which represents one set of viable options for given Project components. The project description is based on early scoping and pre-feasibility studies that have been completed to date by Noront. This description should not be interpreted as being the final or preferred options. Through the assessment of alternative methods and alternatives to as described in Section 4 and in consultation with interested persons the project description will be refined. The final project description will be presented in the EA. 5.1 PROJECT LOCATION The Eagle s Nest Project is a proposed multi-metal mine located in northern Ontario within the James Bay Lowlands. The Project mine site is located approximately 300 km north of Nakina and 530 km northeast of Thunder Bay (Figure 5.1). The approximate geographical coordinates are 52 o N and 86 o W. 5.2 PROJECT RATIONALE Noront has spent considerable time and effort to define a Project which will protect the environment as much as possible and maximize socio-economic benefits. Aside from the locational constraints of the mine determined by the deposit, which obviate alternative sites, Noront has incorporated input from local communities into the design of the Project. Using the input received during early engagement and consultation with interested persons and the data gathered in previous assessments and investigations some of the potential alternatives to and alternative methods have already been evaluated and discarded. The rationale and reasons for discarding certain alternatives are identified in the supporting documentation accompanying the ToR and will be discussed in detail within the EA. Because existing metal mines are near depletion, new developments are required to replace or increase supplies. Noront has an interest in sustaining the production and supply of nickel, copper, platinum and palladium through the Eagle s Nest Project. Developing the Project would contribute to the production of these metals and Noront s strategic goals. Moreover, mining remains an integral part of the northern Ontario economy. As existing projects move through their life cycle, there is an ongoing need to locate and develop new ore bodies to maintain the economy. Mining activities generate considerable direct and indirect economic benefits through employment. Most estimates suggest that there are three indirect jobs created for every direct mining job. The Eagle s Nest Project will contribute many jobs both on and off-site during construction, through the 11 year mine life and during decommissioning. A significant portion of the labour forces will be derived from communities in the region. Along with direct employment to the local First Nations, the Project will bring additional training benefits and business opportunities. The development of the Project will also provide financial benefit to local First Nations and will generate tax revenues for the Province and the Federal government. 14 of 63

23 The major project components include: An underground mine, mill and processing plant for crushing, grinding and flotation of the ore, and dewatering of the resulting concentrate. The end product will be a multi-metal concentrate containing nickel, copper, platinum, palladium and gold mineralization. Other associated infrastructure will be developed (for example, on-site all-weather roads, air strip, explosives plant, as well as, waste and water management facilities) to support the Eagle s Nest mine. Because of the challenging soil conditions in the wetlands, and to minimize environmental impacts, Noront plans to locate as many of the facilities as practical underground. A 90 km pipeline to transport the concentrate to a new facility referred to as Webequie Junction located southwest of Webequie First Nation. A winter road corridor will be developed along the pipeline route to provide access to the mine site. Webequie Junction, where the concentrate will be dewatered and loaded for bulk road transport to Savant Lake along an all-season road to be constructed along an existing winter road corridor A facility at Savant Lake to transfer the concentrate from trucks to rail cars for shipment to Sudbury or elsewhere for further processing A 25 MW diesel-fuelled power generation station at Webequie Junction. The Power generated will be delivered to the mine site via a single circuit 69 kv overhead transmission line. 5.3 PROJECT LIFE CYCLE The Project involves the construction, operation, closure, and remediation of an underground mining facility. Mining of the high-grade nickel-copper-platinum-palladium Eagle s Nest deposit will occur at a rate of 2,960 tonnes per day (t/d), or approximately 1 million tonnes of ore per year. Based on this production rate and currently defined mineral resources, the mine is expected to operate for 11 years Project Phases The Eagle s Nest Project is a complex and extensive undertaking that will occur in phases that differ in their potential interactions with the natural and socio-economic environments and in the occurrence of residual impacts. In order to focus the impact assessment, the project activities are divided into three main categories or phases: Construction Phase: all of the activities associated with preparing the site and supporting infrastructure for operation of the mine will be carried out. Included in this phase is the construction of the access roads to the site, the pipeline, and the electrical transmission line. Operations Phase: all of the activities associated with mining, ore processing, extraction of the ore and concentrate transport will be carried out for the life of the mine. Closure and Post-Closure Phases: all of the activities required to decommission, close and stabilize the mine and associated facilities, are carried out, the activities required to monitor the effectiveness of closure are carried out, and during which the potential for long-term effects is considered. 15 of 63

24 5.3.2 Construction Phase Construction activities at the mine site, at Webequie Junction, and along the access route will require additional accommodations for the construction work force which will be larger than that required to operate the mine. Facilities will be in place to ensure the environmental objectives are addressed through this phase of the mine life. Facilities to support construction will include: Route Construction: Winter and all-season road staging sites will be constructed at the Highway 808 intersection, at Webequie Junction, approximately half way between these locations, and at the mine site. The staging sites other than at Highway 808 will have: o Bunkhouse accommodations and kitchen facilities for 60 people o Water well, treatment, sewage and greywater handling systems o Fuel storage in a bermed and lined area o Parking areas for storing the equipment between ice road seasons o Helicopter landing pad Concentrate Pipeline: The concentrate pipeline will be constructed between the mine site and Webequie Junction. The pipeline will be a small diameter (15cm interior diameter) heavy walled (schedule 120) carbon steel pipe with an external secondary protective reinforcing layer (composite wrap). Construction of the pipeline will occur primarily during the winter when the ground is frozen. The pipeline will be installed below the frost line. Transmission Line: The 69 kv overhead transmission line will be constructed within the same corridor housing the concentrate pipeline and winter road. The overhead transmission line will be constructed during the winter. Further details including construction materials and design will be included in the EA. Webequie Junction: Webequie Junction will be developed for the power generation station and concentrate dewatering and load-out. Facilities during construction will include: o Accommodations for about 100 construction personnel, and associated water and waste treatment o Parking and staging areas for receiving and storing construction materials brought across the winter road Savant Lake: This railcar loading facility will be developed to receive and unload truck drawn trailers of concentrate, store concentrate, then load concentrate onto railcars for shipping to a smelter. Facilities during construction will include: o A construction office o Water and waste treatment Esker Camp: The existing exploration camp, located east of the Muketei River, will continue to be used for regional exploration activities. The final site accommodations will be built early to house construction crews, expected to peak at approximately 600 people. Double occupancy of rooms will be applied during construction and later changed to single 16 of 63

25 occupancy during mine operation. Initially, while the permanent camp is being built, the Esker Camp tent facility will be expanded. During the construction phase, equipment will be transported and site preparation activities will be undertaken. Clearing and grubbing, and site levelling will be undertaken where infrastructure is to be placed. Site drainage will be constructed in the initial stages. Drainage will be directed to treatment facilities to ensure that runoff does not cause erosion, flooding, or contamination in downstream areas. The all-season access road will also require aggregate which will be sourced from licenced and/or permitted aggregate sites. During these activities, erosion protection will be constructed to limit runoff and sedimentation in adjacent watercourses. The site infrastructure, including a water supply pipeline, storage and maintenance areas, permanent support facilities such as a paramedic station and offices will be constructed. Construction of facilities where potentially hazardous materials are stored or used, such as fuels and lubricants will include mitigation measures, such as impermeable surfaces and spills containment and clean-up equipment, in order to minimize potential environmental impacts. Fuel storage areas will be constructed and spill containment and cleanup materials will be maintained on-site. A pad to prevent seepage of spilled materials into the underlying soil/rock will be constructed. Domestic wastes products produced during the construction phase such as food scraps, packaging and recyclables as well as special wastes/hazardous wastes will be sorted, compacted and shipped off-site to a licensed waste disposal site. Domestic sewage will be treated by an appropriately sized septic system or a sewage treatment plant such as a rotating biological contactor (RBC). Effluent meeting regulatory requirements will be discharged directly to the environment Operations Phase During the operations phase, the process of removing the ore though development of an underground mine will begin. Because of the challenges of developing a mine in a wetland, Noront plans to locate as many of the facilities as possible underground, as has been done elsewhere in the world in similar landcover. To maximize the use of competent rock beneath the surface, the mine, mill, warehousing and shops will all be located underground. Surface facilities will include living quarters, some administration offices, an airstrip, the mine portal, a small explosives plant, and staging areas for activities associated with surface access. Aggregate material will also be sourced underground to be used for construction of the minimal surface facilities. A powerhouse will be built south of Webequie, at Webequie Junction, outside the Lowlands, connected to the site by transmission lines. A buried pipeline will transport the nickel-copper concentrate from the mine site to a concentrate load-out facility next to the powerhouse. Tailings 17 of 63

26 will be thickened and stored underground in empty production and aggregate stopes, either with or without cement addition. An all-season road and winter road will connect the Project to the existing provincial infrastructure. The all season road will provide connectivity between Webequie Junction and the Savant Lake Concentrate Transfer Facility. During peak production it is anticipated that shipping would occur at a rate of 20 truckloads per day. The all-season road would also support the transportation of fuel and supplies to and from Webequie Junction and the mine site during winter months. During the operations phase, the all-season road may also be used by the public. A road use management strategy will be developed for the road in consultation with the Ministry of Natural Resources. In addition to the mine workings and the processing plant, the operating phase includes a number of facilities to support the mining operation. These include worker facilities (including First Aid facilities), offices and laboratories, and facilities to support these functions, such as sewage treatment facilities, waste disposal, and potable water supply. Domestic sewage will be treated on-site at the wastewater treatment plant, and discharged from the site. Solid wastes not suitable for incineration from the mine, offices, workshops and laboratories will be disposed of in solid waste management facilities. The wastes will be sorted, compacted and shipped off-site to a licensed waste disposal site. The waste management facility will be fenced off to prevent nuisance animals including wolves and bears from accessing potential food sources Closure and Post-Closure Phase The closure phase includes a list of activities that are designed to ensure that the Project site is closed in a manner that reduces the potential impacts on the social and natural environment. In the closure phase, the mining activities are terminated and dismantling and closure of the site begins. This includes the closing of domestic waste management areas in an environmentally acceptable manner. Closure also involves the progressive rehabilitation of disturbed sites through the removal of infrastructure that will not be needed during future phases of the Project. For example, progressive rehabilitation could take place at road staging sites, fuel storage areas, helipads, access roads to aggregate sites. Closure activities include the removal of materials and equipment from Webequie Junction, Savant Lake and the Eagle s Nest site and the removal of hazardous materials and wastes to a licensed disposal facility by a licensed contractor. Reclamation of the sites will be undertaken to enhance natural recovery of the disturbed areas and allow for future use by people and wildlife. Mine Closure plans will follow the guidelines established in the Mining Act by the Ministry of Northern Development and Mines. 18 of 63

27 The following summarizes the various components of the Project requiring remediation and closure: Underground Mine and ancillary facilities Surface infrastructure (accommodations building, services complex, access portals, etc.) Aggregate rock piles Slurry pipeline Fuel storage Waste and water management facilities Explosives Contaminated soils Roads and airstrip Transmission line Some of the above components may be left in place pending negotiations with First Nations and provincial and federal Governments. These may include, the airstrip, all season and winter roads and transmission lines. Closure activities also include monitoring at the mine site and other sites requiring closure, which will be defined in the Closure Plan, during post-closure and closure. Monitoring for surface water quality, groundwater quality and physical stability of all mine related works will take place for a defined period of time determined through consultations with the government and Aboriginal communities and stakeholders. Monitoring typically occurs for a minimum of five years after closure. Biological monitoring programs may also be required after closure. Details of the activities to take place during closure and post closure will be provided in the Mine Closure Plan required under the Mining Act. 5.4 PROJECT DESCRIPTION SUMMARY Mine Development Mining operations will be conducted using underground mining techniques involving drilling and blasting, and movement of ore to a concentrator (mill). The bulk concentrate produced in the mill will then be transported by a slurry pipeline to a handling facility, filtered and trucked to a rail head and later transported via rail for further processing. Operations will include the production of aggregate materials and backfilling of stopes. A ramp from surface will provide access to the mine workings. A spiral ramp will be continued to a depth of approximately 1,200 m adjacent to the ore body to connect the production levels and transport the ore to the mill. Ore will be processed underground resulting in two products, concentrate slurry and backfill. All waste products from the milling circuit will be stored underground as paste or cemented paste backfill. 19 of 63

28 5.4.2 Mine Design The following parameters were used as the preliminary design basis in the mining section for the Eagle s Nest Project: Design based on an indicated resource of 11 Mt from 10 m below surface to 1,200 m below surface Design production rate of 2,960 t/d of sulphides, plus 350 t/d of aggregate rock and 1,000 t/d of waste, bringing the required mining rate of ore, waste and aggregate to approximately 4,300 t/d Foot wall and hanging wall rocks and ore are of generally competent description and strength Surface overburden is from 5 m to 20 m deep and 100% saturated Ore body sections to be developed in vertical blocks, varying in height from 100 m between sills to 150 m with 50 m sub-levels Crown pillar at 75 m L to surface; 50 m sill pillars separate mining blocks - to be mined at end of mine life The specific gravity of rock = 2.7, bulk in situ ore = 3.0 and tailings slurry = 1.57 at 50% density (solids by weight) Ore Processing Rock from the initial underground development will be trucked to surface to be used as aggregate or other fill material for surface infrastructure. Initial geochemical tests on this material show it to be suitable for this purpose; however, testing during extraction will ensure this is the case. Any sulphide bearing rock will be segregated and stored on site temporarily until it can be placed in aggregate stopes later. While on surface, the water run-off from any stockpile will be collected, tested and treated before release to the surrounding peat bog. Aggregate crushing, screening and stock piles will be located on surface near the portal area. This area will drain to a settling pond to remove sediment before release to the bog. When the mine is in production, rock from development workings will be sent to surface if suitable for use as aggregate or it will be placed in open stopes as backfill. The management of tailings is discussed in Section Concentrate Handling and Storage Concentrate will be pumped in a slurry pipeline from the mine site to a dewatering and storage facility situated at Webequie Junction. The concentrate system will include: A 300 m 2 heated filtration plant complete with thickeners, filter press and associated equipment A concentrate filtrate storage and load out facility A 2,500 m 3 water pond near the filtration plant A 90 km concentrate slurry pipeline with a nominal capacity of 800 tonnes per day and a peak capacity of 1300 tonnes per day Two pump stations 20 of 63

29 The pipeline will be a small diameter (15 cm interior diameter) heavy walled (schedule 120) carbon steel pipe with an external secondary protective, reinforcing layer (composite wrap). It will be buried below the frost line in the wetland. Welds will be inspected with X-ray non-destructive testing equipment during construction. Pressure and flow transducers will be employed along the length of the pipeline to monitor its condition by continuously measuring the hydraulic gradient. Signals from the instrumentation will be relayed to the process control centre so operators will receive an alarm if readings indicate a problem. To avoid instrumentation errors causing false stops of the pipeline, more than one gauge will be used to determine if a failure has occurred. If the operator does not respond to alarms after a short duration, the system will turn off the pumps. Pipeline inspection employs a pig, which is a non-destructive testing device just smaller than the inner diameter of the pipe, which is pumped through the pipeline and uses magnetic flux leakage and ultrasound to inspect the condition of the pipe walls. Inspection data are stored on the pig and recovered when it exits the pipe at the discharge. Repairs to the pipeline would have to be carried out with helicopter support for most of the year, except in winter. This would include developing temporary work pads adjacent to the pipeline for excavation and repair of the damaged section, and recovery of contaminated soils. Most of the water to be used to carry concentrate to Webequie Junction will be pumped back to the mine site in the same pipeline and reused for processing. Some water (48 m 3 /day) will be retained as moisture in the concentrate. Dryers will use recovered heat from the power generators to reduce moisture in the concentrate before it is shipped. The dried concentrate will be stored in hopper bins and discharged directly to truck trailers positioned on a weigh bridge in an enclosed truck filling bay. From Webequie Junction, concentrate will be trucked to a rail transfer facility near Savant Lake, described below. Trucks towing trailers with 40 tonne capacity are proposed. The trailers will be covered to prevent dust emission during transit. At peak, up to 20 truckloads per day would be transported. The Savant Lake railcar loading facility, to be developed along the existing rail line, will include a storage shed to hold 1,200 tonnes of concentrate, approximately one day of pumping at peak capacity. Truck trailers will drive into the shed to unload. An in-floor conveyor will transfer concentrate to railcar loading equipment which uses retractable dust control chutes to contain dust during railcar loading operations. Lands for this facility may be acquired or supplied by the transportation company, but the impact will be reviewed by Noront. Based on the current site layout there will not be a need to obtain Crown Land for the Savant Lake Facility. This loading facility is located within continuous caribou habitat and specifically within the Brightsand Caribou Range. New facilities with the permanent road systems will be rationalized with the existing approved FMP planning and cumulative disturbance management objectives for the Brightsand Range. 21 of 63

30 5.4.5 Explosives Production An emulsion explosives plant will be constructed south of the portal at an appropriate Quantity-Distance separation, according to Explosives Regulatory Division requirements. Sensitizer for the emulsion, which renders it explosive, will only be mixed into the emulsion during loading operations at the blasting areas underground. Non-explosives raw materials will be transported to the site and stored at a suitable separation distance from this facility. Magazines for detonators, boosters and some emulsion explosive cartridges (stick powder) will be constructed at suitable separation distances from other mine facilities and the explosives plant Power Supply Power will be provided by ten 2, 700 kw capacity diesel generator sets (9 operating), providing up to 25 MW of power. Total estimated mine site power demand is 17 MW. A single building will house the power generation plant, switchgear and controls. Two 13.8/69kV step-up transformers, each rated 30/40 MVA ONAN/ONAF, will feed the 90 km single circuit 69 kv overhead transmission line to be installed to deliver power to the mine site. At the mine site a Transformer Station (TS), equipped with two 69/4.16 kv, 30/40 MVA, transformers, will provide power to distribution feeders serving the mine and its surface facilities. Three fuel tanks (900 m 3 each) will be included at Webequie Junction to provide 3 weeks storage of diesel fuel to power the generators. These fuel tanks will have secondary containment in compliance with regulations. If the mine converts from mostly diesel mobile equipment to electric powered equipment, the overall electrical power requirement will not be significantly impacted. The switch to electrical equipment will increase the electrical demand for mobile equipment, but this increase is expected to be offset by reduced power for mine ventilation air required by the use of diesel powered equipment. A diesel fuelled generator and transformer at the mine site will provide 2 MW of emergency power. Fuel will be stored in diesel storage tanks that supply fuel to underground fuel stations for diesel powered equipment. During site construction, this generator will provide power for the mine and other electrical demands. It will be temporarily located in a contained area adjacent to fuel drum storage. Once the Webequie Junction generators provide power to the site, the backup generator will be repositioned near the main camp facilities Water Supply Wells will be installed to draw water for the mine, mill, and surface operations. Water will be supplied to a fresh water tank on surface at the above ground mine site complex. A 150 mm 22 of 63

31 diameter fresh water line will be lowered down a drill hole to supply the processing plant and mine. An insulated and metal-clad combined-duty fire and potable water storage tank will be installed. Water is to be supplied from the fresh water storage tank, through a potable water treatment plant. The treatment plant and pumps will be housed in a pump house building of pre-engineered construction. A buried and insulated HDPE pipe will deliver the water to the surface facilities. Fire water will be supplied to a buried distribution pipe main in the yard and to the underground mine through a pipe in a second drill hole Waste Management Mine Waste Rock Waste rock from the initial underground development will be trucked to surface to be used as aggregate or other fill material for surface infrastructure. Aggregate crushing, screening and stock piles will be located on surface near the portal area Tailings Management All of the tailings produced by the mill will be kept underground. Most will be turned into cemented paste backfill and stored in production ore stopes. The remainder (estimated to be 20 to 30% of tailings produced) will be dewatered and stored in aggregate stopes excavated in the host granodiorite rock mass. Seepage water from backfill and aggregate rock stopes will be pumped back to the mill for treatment and re-use. The aggregate stopes will be situated in the host rock between the 75 m L and 125 m L, away from the shaft, ramp and mill infrastructure. The stopes will be mined out using the same production practices as the ore stopes using a blast hole method with long hole drills. Additional cavities within the 125 m L to 175 m L horizon will be excavated to provide rock handling infrastructure (coarse rock pass, crusher/screen plant, crushed rock product passes and bins). The demand for aggregate will be largely during the construction phase of the project for use on surface as fill material, aggregate rock for forming the sites for infrastructure, and as the aggregate component of concrete. Thus, the aggregate stopes will be available from the start of production for holding waste rock and tailings Organic and Solid Waste Waste products include domestic waste such as food scraps, packaging, and refuse. Inert waste such as glass, scrap metal and clean plastics will also be produced. Due to the location of the Project a below grade landfill site is not possible for the disposal of non-hazardous materials. The most suitable way to dispose of nonhazardous waste on 23 of 63

32 site is through incineration. An incinerator will be the primary means of disposing of domestic waste during the construction, operation and closure phases of the Project. Materials not suitable for incineration such as recyclables including; plastic, tin, and glass, will be sorted compacted and stored until they can be shipped out. Similarly, scrap metal will be stored on-site with the recyclables until it can be shipped off site or reused. Large wood packaging will be burned on site or transported off-site as appropriate. A proposed dual chamber manual incinerator with a minimum residence time of one second in the combustion zone at minimum combustion temperature will be used. Waste passing through the primary chamber is burnt resulting in volatile gases and soot travelling to the secondary high temperature chamber for additional incineration. This product is then sent to either a wet or dry scrubbing system. Details surrounding monitoring of the emissions will be determined through the Provincial air emissions approval process Hazardous Waste Wastes falling under this category include but are not limited to, biomedical waste, contaminated soils, used petroleum products, and petroleum contaminated containers. These wastes will be handled and stored in sealed containers in lined and bermed areas or in secondary containment. These materials will be sent off-site to the appropriate licenced facility. However, contaminated soils will be treated onsite in a bioremediation area. Used glycol and lubricating oils will be stored in tanks and sent off-site to a licensed disposal facility. All contaminated liquids will be stored in clearly marked containers and sent to a licensed disposal facility. Fuel tanks will be stored within the fuel storage area and returned to the vendor. If the containers are not returnable they will be cleaned, crushed and stored on-site until they can be shipped off site. Explosives waste created on-site will be destroyed according to approved methodology by the explosives contractor or by licensed personnel Sewage Treatment The proposed sewage treatment system is a rotary biological contactor (RBC) plant fed by a pair of alternating duty, constant feed submersible pumps, installed at the bottom of an adjacent in-ground concrete surge tank and pump chamber. This facility will require a certificate of approval from the Ministry of the Environment, under the Ontario Water Resources Act, for industrial sewage works Access Roads The Eagle s Nest Project is situated in a remote undeveloped area of Northern Ontario. Access to the Project is currently limited to aircraft as there are no existing all-season or winter roads 24 of 63

33 capable of providing access to the proposed mine site. An existing winter road currently runs from Hwy 808 to Webequie First Nation, passing by the proposed Webequie Junction site. First Nations that rely on this winter road include Webequie, Nibinamik, Eabametoong, and Neskantaga. As a result of terrain analysis and alternatives assessments conducted by JD Mollard and Associates as well as SNC-Lavalin Inc., included in the supporting documentation, and Nuna Logistics, a proposed preferred access corridor has been identified. The access road will consist of an all-season segment and a winter road segment. The all-season road will run from Highway 808, roughly 60 km north by northeast of Pickle Lake, to Webequie Junction. This section will require the realignment and upgrading of the existing winter road into an all-season road. The second section will consist of the construction of a winter road between Webequie Junction and the proposed Eagle s Nest mine site. All-season Access Road A public access all-season road of approximately 225 km in length is being proposed from Highway 808 to Webequie Junction. The all-season road will follow along the existing winter road to the greatest extent possible. By following the existing winter road the amount of newly disturbed habitat will be minimized and is expected to reduce the project s footprint and environmental impact relative to building a road through pristine landscapes. It is important, however, to conduct sub-range and range level caribou studies to assess road construction and operation impacts on caribou habitat values including spring to autumn season habitat functions. Approximately 70 water crossings have been identified along the proposed all-season access corridor. Construction of the all-season road will provide an economically viable means to transport the concentrate from the mine to the proposed railhead which will be located near Savant Lake. Construction of the all-season access road will consist of the following activities: Clearing and grubbing a right of way approximately 33 m wide, following the existing winter road to Webequie to the greatest extent possible One major river crossing over the Pineimuta River Topsoil stockpiled along the right of way Material unsuitable for construction distributed along the right of way Aggregate sourced from licenced or permitted sites including rock quarries and eskers Construction camps Mobilization and demobilization of crews and equipment Winter Road In order to minimize the potential adverse environmental effects to the James Bay Lowlands, and due to the technical challenges of building roads on peat bogs, a winter road approximately 90 km long is proposed to be developed to connect the Webequie Junction site to the 25 of 63

34 Eagle s Nest mine site. The winter road will enable materials such as consumables and wastes to be transported to and from the mine site. The winter road concept was selected based on initial constructability and in order to minimize impacts on the wetlands. It remains, however, to evaluate the potential impacts of this winter road on sub-range and range scale caribou habitat and population functions. Construction of the winter road will consist of the following activities: Clearing a right-of-way to a minimum width of 7 m with slash being pushed to the edges as necessary and burned, piled, angled etc. to facilitate the movement of caribou Installation of a permanent bridge across the Muketei River Installation of temporary bridges Packing and icing of the road Construction activities will primarily take place in the winter after the ground has become sufficiently frozen. Limiting construction activities to this period will help reduce environmental impacts associated with road construction. Installation of temporary bridges and culverts will be planned around spawning and fish migration periods. Temporary water crossings will be removed prior to thaw and the initiation of fish migration to avoid inhibiting fish passage. Savant Lake Concentrate Facility Access Road Access to the proposed facility is provided by existing gravel forestry roads. The existing forestry roads may require upgrading to handle the increased traffic. Noront will ensure that the appropriate work permits are obtained before any modifications to the existing roads are made Airstrip An airstrip will be built to the dimensions of 150 m wide by 1,870 m long, suitable for the various aircraft expected to use it, including the Lockheed-Martin Hercules class cargo transporter. Rock from the underground development areas will be crushed and sized to prepare appropriate granular material for the gravel runway Support Facilities A single Services Building Complex for multiple uses has been designed. This building will include the administration and engineering office, warehouse, mine dry, nursing station, assay and environmental laboratory, surface maintenance shops, health & safety and training rooms. An accommodation building is currently being designed to hold approximately 350 beds (700 with double occupancy in rooms), including an allowance for transitional occupancy during turn-around and for inoperable occupancy. It will be attached to the services building complex. 26 of 63

35 6.1 INTRODUCTION SECTION DESCRIPTION OF AND RATIONALE FOR ALTERNATIVES The OEAA refers to two different types of alternatives: alternatives to a proposed undertaking and alternative methods to a proposed undertaking. As defined by the MOE, alternatives to are defined as functionally different ways of approaching and dealing with a problem or opportunity ; while alternative methods are defined as different ways of performing the same activity (MOE, 2009). The assessment of a wide range of alternatives is essential to the EA planning process in Ontario. The following sections provide details about the various alternatives to and alternative methods that will be examined in the EA. Tables 6.1 and 6.2 summarize the list of alternatives to and the preliminary list of alternative methods that will be assessed in the EA. As indicated in Section 4, Noront is focusing the assessment of alternatives, and the EA will be prepared in accordance with Sections 6(2)(a) and 6.1(3) of the OEAA. 6.2 SELECTION OF ALTERNATIVES To determine the range of alternatives to be evaluated in the EA, the following aspects were considered, as outlined in the Code of Practice: Preparing and Reviewing Environmental Assessments in Ontario (MOE, 2009): Do they provide a viable solution to the problem or opportunity to be addressed? Are they proven technologies? Are they technically feasible? Are they consistent with other relevant planning objectives, policies and decisions? Are they consistent with provincial government priority initiatives? Could they affect any sensitive environmental features? Are they practical, financially realistic and economically viable? Are they within Noront s ability to implement? Can they be implemented within the defined study area? Are they appropriate to the Noront Project? Are they able to meet the purpose of the Environmental Assessment Act? In addition, alternatives were also selected based on input received during consultations with regulatory agencies, the public and Aboriginal groups. 6.3 ALTERNATIVES TO Alternatives to the proposed undertakings are shown in Table 6.1. Alternatives to have been indicated for the major components of the Project including the: Eagle s Nest Project Transportation Corridor Airstrip Concentrate Shipping Webequie Junction Transfer Facility 27 of 63

36 Savant Lake Concentrate Facility Power Generation Mining Methodology Tailings Management Waste Management As indicated above, Noront has opted to focus the EA and has screened out a number of alternatives to that do not warrant being carried forward into the EA. These exclusions are based on a number of pre-ea planning studies, including scoping and feasibility level studies. As indicated in Table 6.1, the following alternatives to are not going to be considered in the EA: Transportation corridor (Site Access) o Railway o Hovercraft o Aircraft Power Generation o Hydroelectric o Solar o Natural Gas o Wind Rationale behind the exclusion of these alternatives to in the EA is provided in the supporting documentation. It should be noted that Table 6.1 provides a preliminary list of alternatives to and additional alternatives to may be identified during the EA process. 6.4 ALTERNATIVE METHODS OF CARRYING OUT THE PROJECT Table 6.2 provides an overview of the alternative methods that will be addressed in the EA. The list of alternative methods may be redefined once a preferred alternative to has been selected for each component. It is possible that additional alternative methods for a proposed undertaking will be identified during the EA process. Work has been carried out by Noront, in consultation with communities and other groups to optimize the Project and minimize potential environmental impacts through construction, operation closure and post-closure phases. As indicated in Table 6.2, the following alternative methods will not be considered in the EA: Transportation Corridor (Site Access) o North-South corridor Mining Methodology o Open pit mining methods 28 of 63

37 Savant Lake Transfer Facility o Location of the Facility Webequie Junction Facility o Location of the Facility Rationale behind the exclusion of these alternative methods in the EA is provided in the supporting documentation. The final EA will provide a description of the alternative methods and rationale for their selection and assessment. 29 of 63

38 SECTION DESCRIPTION OF THE EXISTING ENVIRONMENT AND POTENTIAL EFFECTS OF THE PROJECT 7.1 PROJECT DESCRIPTION The EA will provide a final description of all the components of the Project, in order to identify the interactions of each component with the physical, biological and socio-economic environment in the Project area. The description will be sufficiently detailed to enable identification and assessment of impacts for each of the phases in the Project life cycle (construction, operations, closure and post closure). The description of the Project will include information on the: Purpose and rationale for the Project Regional and local geology, including an analysis of the ore body Project components including descriptions of: The Project footprint The materials to be used Technologies, procedures and processes The products, by products and waste generated Hazardous materials, water and waste management systems Workforce accommodation, management and training Implementation plans, costs and schedules Closure and post closure plans The project description will also provide details on alternatives considered in the finalization of the Project design and the rationales for choices made. Noront s current scoping study methodology includes trade off studies that investigate certain alternatives on the basis of both the cost effectiveness and the potential environmental and social effects of different options. The following section provides a preliminary description of the Project. 7.2 IDENTIFICATION OF STUDY AREAS The following sections are a preliminary description and the final detailed description of all environmental components will be provided in the EA General Study Area The significance of an impact to the environment depends in part on the geographic extent of the impact. As such, an impact assessment will be considered with respect to specific study areas. For the purposes of this assessment, the impacts will be considered with respect to the areas of project development. The potential impacts of the Project will be assessed on the basis of local and regional areas around proposed facilities: The Mine Site Study Area: this is the area containing the mine infrastructure, the deposit, and associated servicing and maintenance areas (Figure 7.1). 30 of 63

39 The Webequie Junction Study Area: this area includes the concentrate transfer facilities, power generators, and an area around the site where impacts could be expected (Figure 7.2). The Savant Lake Study Area: this area includes the transfer facilities and an area around the site where impacts could be expected (Figure 7.3). The Access Road Corridors Study Area: this includes areas along the proposed all-season and winter road access corridors, transmission lines and pipeline corridor (Figure 7.4). The Regional Study Area: this includes all of the above areas, and extends beyond the Local Area (Figure 7.5). The exact extents of the study areas will be finalized and defined in detail in the EA. The size and extent of the study areas may differ for each environmental study component. For example, the study area for assessing terrestrial biological effects (e.g., caribou migration) will likely be more extensive than the hydrological study areas. Watershed boundaries will be utilized to define and delineate the regional study area to ensure that potential impacts on an entire watershed are considered. The EA will define specific study areas as noted above for each of the study components, and each component will either be assessed within the regional study area or within the local study areas as determined by the baseline studies or the effects assessments Caribou Study Area The local and regional study areas will incorporate the potentially affected caribou range or ranges. Cumulative effects of this Project, as well as other developments in the Ring of Fire on caribou will be assessed as directed by the Ontario Caribou Conservation Policy under the ESA (2007). Noront is currently a member of the MNR working group which aims to develop resource selection modelling for caribou in the Ring-of-Fire region. One of the objectives of this work is to define caribou population ranges, which will assist in defining the study area necessary for the Project s caribou component. This includes the mine site, the proposed transportation corridor and the aggregate pits and service roads associated with it. Appendix B provides a summary of the Ontario Woodland Caribou Recovery Strategy and the Ontario Woodland Caribou Conservation Plan, and it describes anticipated information needs and analyses. 7.3 GENERAL SITE INFORMATION Current access to the exploration site at Esker Camp is by helicopter or plane equipped with floats in the summer, and skis and/or wheels during the winter. Flights typically originate from, Nakina located 300 km to the south, from Pickle Lake which is located 300 km west southwest, or from Webequie, located 80 km west northwest. The Koper Lake, located 3 km to the east of the camp serves as the main access point for float planes and is used to construct the winter ice strip. Nakina is accessed by all-season road and rail, while Pickle Lake is accessible by all-season road. Both centres have paved airstrips. The deposit is located adjacent to the Muketei River on and near a series of esker deposits. The local area consists of considerable wetland areas and small isolated water bodies. 31 of 63

40 Environmental Baseline studies were initiated by Noront in 2009 and have been ongoing since then. Preliminary results were discussed with provincial ministries in May, Their comments were reviewed and applied for planning 2011 baseline studies. 7.4 PHYSIOGRAPHY, GEOLOGY AND GEOCHEMISTRY The regional study area is underlain by Precambrian rocks of the north-western part of the Archean Superior Province. The Superior Province is a part of the central region of the Canadian Shield and is the world's largest contiguous exposed Archean craton. A series of Meso-archean volcanic and plutonic belts trending from west to east formed as micro-continents and are separated by Neo-archean meta-sedimentary belts and crustal faults. Eagle s Nest is a volcanogenic massive sulphide deposit lying within a significant greenstone belt located at the eastern limit of exposure of the Oxford-Stull Domain, where it disappears under the Paleozoic cover. The greenstone belt is not fully understood due to the lack of exposed supracrustal rocks in the region. Interpretation is almost exclusively through airborne geophysical surveys and diamond drilling. Surficial material in the region consists of unstratified post glacial till interspersed with bedrock outcrops and stratified till. The surficial material at the mine site is predominantly silty clay loam, of marine and lacustrine origin, overtop coarser sands of an esker deposit. Soil development in the region varies depending on drainage. Low lying areas consist of organic soils, while better drained soils are regosolic. Screening level environmental testing and chemical analyses were conducted on granodiorite and ultramafic intrusion samples, obtained from diamond drill holes. These tests were conducted to determine whether the aggregate materials sourced from underground will be suitable for construction aggregate. The samples were subjected to standard extraction tests and chemical analyses used to estimate the short and long-term solute release from rock produced by natural weathering. These included analyses to determine: The ultimate potential of this material to generate acidic leachate (based on acid/base accounting (ABA) analyses) The short term potential of this material to produce leachate that contains metals or other regulated solutes at concentrations above regulatory discharge standards (using synthetic precipitation leach tests (SPLP) modified to 1:4 rock:water ratio) The ultimate potential for dissolution of metal and other regulated solute by long term oxidation (using the peroxide oxidation net acid-generating potential (NAG) test) Results of these tests show that the granodiorite and granodiorite with mafic intrusion are not acid generating. Test results show that the granodiorite and mafic intrusion had a neutralization potential of at least 3 times greater than its acid generating potential. Several solid phase metal concentrations were below detection limits including arsenic, bismuth, antimony and selenium. Nickel was present in concentrations of 5.5 to 10 ug/g and Copper concentrations ranged from 5.5 to 50 ug/g. 32 of 63

41 Primary constituents of potential concern are probably arsenic and vanadium from the deeper mafic dyke/granodiorite rock. These two elements currently exceed the Provincial Water Quality Objectives (PWQO) standards in both effluent from the meteoric-water leach test and the NAG-test leachate on the deeper rock. Both of these elements can have moderate to high mobility in the environment. Aggregate rock will come from other sources, confirmed by testing of source rock. Other elements that exceeded the PWQO standards include aluminium, copper, chromium, silver, and hydronium ion (i.e., ph). However, these elements are unlikely to be of actual concern because they are highly reactive in natural environments. Thus, little buffering would be required to reduce the ph to below PWQO standards (ph 8.5) and these metals tend to adsorb strongly to mineral surfaces and/or precipitate rapidly at near neutral ph. As a result, contents of these constituents are likely to drop quickly when effluent from this rock encounters soil or aquifer materials. In more sensitive areas it is possible to remove solutes from the leachate by simple treatment (e.g., flocculation in a settling pond) or through light amendment of the granodiorite with a chemical adsorbent. Additional geotechnical and chemical testing is ongoing. When reported, the test results will be applied to the design of the Project. 7.5 CLIMATE AND METEOROLOGY The James Bay Lowlands area of northern Ontario has a humid continental climate with cool short summers and cold long winters. The area has a perihumid high boreal ecoclimate and does not experience a dry season. The local climate is affected by the proximity to Hudson Bay and James Bay. Fog is common in the early morning and may last all day during the summer months. There are usually 1 or 2 days of dense fog in the summer that restrict the use of aircraft. There are typically 2 or 3 days during the winter months when snow storms restrict activity in the region. The following weather statistics are based on data collected from the Environment Canada meteorological station at Lansdowne House (approximately 130 km to the southwest) from 1971 to 2000: The average daily temperature is -1.3 C o Summer temperatures are generally between 10 C and 20 C with a mean July temperature of 12 C and a mean maximum summer temperature of 22 C. The extreme maximum summer temperature is 37 C. Winter temperatures are generally between -10 C and -30 C with a mean January temperature of -21 C and a mean minimum temperature of -27 C. The extreme winter minimum was -48 C on January 19, 1943; and an extreme wind chill of -58 C was recorded on February 11, o The period from mid-june to mid-september is generally frost free o Lakes start to freeze in mid-october and start to thaw in mid-april o The average annual precipitation is mm with approximately mm falling as m of snow. Measurable precipitation falls on an average of 169 days during the year with snow falling on 89 of those days o The average snow depth is 65 cm in February o Winds average between km/hour depending on the month, and blow from the west to northwest in the winter and from the west to southwest in the summer. In May, however, winds are predominantly from the northeast o Easterly winds commonly bring fog from James Bay and are associated with heavy precipitation 33 of 63

42 7.6 HYDROLOGY Surface water includes water accumulating on the ground in wetlands, lakes and streams. The Project is situated within the Attawapiskat, Ekwan and Winisk watersheds. The Attawapiskat watershed is approximately km 2, the Ekwan watershed is approximately km 2 and the Winisk watershed is approximately km 2. Both the Attawapiskat and Ekwan watersheds drain northeast into James Bay while the Winisk watershed flows north into Hudson Bay. Streams in the study region are low gradient and have low velocity flow throughout most of the year. The stream banks are typical of low gradient streams and well defined by earth, boulders, bedrock outcrops and natural levees. Beaver dams are common features on small to medium sized streams. Stream flow peaks in the spring as a result of snowmelt runoff and rainfall runoff from saturated soils. Flows recede through the summer and increase in the fall due to an increase in rainfall and decrease in evaporation. Flows are normally lowest in winter and small streams freeze completely to the stream channel bed. Snowfall is an important component of the hydrologic cycle in the region as accumulated snow represents a significant stored water component. 7.7 HYDROGEOLOGY The James Bay Lowlands are characterized by predominantly flat, poorly drained soils with slow rates of plant decay. As a result, the development of organic soils and peat is common throughout much of the area. The organic surface layer typically ranges from 3 to 5 metres in thickness. It is underlain by a clay/silt till layer of up to 2 metres thick, and a Quaternary till layer of up to 5 metres thick. Depth to bedrock ranges from 5 to 12 metres below the surface. Stream systems are cut minimally into the landscape, have low slope and slow flows. Due to low relief and low permeability soils, the streams are connected to the overburden aquifer and are not connected to deeper bedrock aquifers. The groundwater table in the overburden is typically at or near the surface due to the flat terrain, and underlying low permeability silts and clays. Where the low permeability overburden material exists, the shallow overburden aquifer is isolated from groundwater in the deeper bedrock. The permeability of the bedrock is expected to decrease with depth and, in general, the most permeable bedrock aquifer will occur along the bedrock/overburden interface. Glaciofluvial esker deposits are common in the Project Area. Eskers are ridges which typically consist of a core of stratified sands and gravels. In esker deposits, the soils are much better drained, there is little surface organic material, and the groundwater table is further below the surface. Eskers are of particular interest for the caribou habitat values analysis at the sub-range and range scales. Being a small proportion of the landscape, eskers may have functions proportionally greater than their area alone might suggest. The well-drained terrestrial vegetation on top with full sized trees and forest cover (absent in the wetlands), and abundant ground lichens may play an important role in seasonal caribou habitat use. Baseline groundwater studies are being conducted to characterize the existing groundwater regime and to support the definition of potential impacts, mitigation measures, monitoring and contingency planning as mine planning proceeds. These baseline studies will be undertaken as part of the EA. 34 of 63

43 7.8 WATER QUALITY Baseline surface water quality is being monitored at 11 sites around the mine site and five sites at Webequie Junction and 2 sites at Savant Lake. Groundwater quality is being monitored in seven shallow overburden wells and four deeper bedrock wells around the mine site. Groundwater monitoring wells have also been developed at Webequie Junction and Savant Lake. Preliminary surface water quality sampling shows that the water at the mine site generally falls within the Provincial Water Quality Objectives (PWQO) for the protection of aquatic life and the Canadian Environmental Quality Guidelines (CCME). However, iron, aluminum and to a lesser extent cadmium, copper and zinc exceeded PWQO and CCME guideline limits. In situ ph levels did not meet the PWQO or CCME guidelines in at three of the 11 sites sampled. Dissolved oxygen also exceeded PWQO guideline limits at two of the sites. Preliminary ground water data indicate that several parameters exceed the PWQO and CCME guideline limits. Iron exceeded both PWQO and CCME guideline limits in most of the groundwater wells sampled. Aluminum exceeded both CCME and PWQO guideline limits at some locations while remaining below method detection limits (MDLs) at others. Additional metals that exceeded PWQO limits include cobalt, nickel, tungsten and zinc. The ph was slightly alkaline with a range of 7.3 to BIOLOGY Terrestrial Environment The Eagle s Nest Project is located within the Boreal Forest of Ontario and includes project components located within two of Ontario s Ecoregions. The eastern portion of the Project area, which includes the proposed mine site and much of the proposed pipeline, is located in the James Bay Lowland Ecoregion and the western portion of the Project area, which includes all of the proposed all-season access road, is located within the Big Trout Lake Ecoregion. Both ecoregions are characterized by cool, short summers and cold winters with a mean annual temperature of approximately -2 C. Mean summer temperature is 11.5 C for the James Bay Ecoregion and 12.5 C for the Big Trout Ecoregion. Mean winter temperature is -16 C for the James Bay Ecoregion and -17 C for the Big Trout Ecoregion. Mean annual precipitation ranges from mm for the James Bay Ecoregion and from 550 mm in the northeast to 775 mm in the southeast in the Big Trout Ecoregion. The main geological difference between the two ecoregions is the presence of flat, poorly drained plains underlain by flat-lying Palaeozoic limestone bedrock with a surficial layer of primarily organic soils in the James Bay Lowlands, in contrast to the crystalline Archean bedrock (Canadian Shield) forming broad, sloping uplands and lowlands dominated by mineral soils in the Big Trout Ecoregion. 35 of 63

44 Most of the James Bay Lowlands is poorly drained with dominant vegetation consisting of sedges, mosses, and lichens with or without stunted Black Spruce and Tamarack. Wetlands cover up to 75% of the ecoregion in certain areas and are composed mainly of northern ribbed fens, northern plateau bogs, and palsa bogs. In the southern portion of the ecoregion and along rivers, the forests are composed of Balsam Fir, White and Black Spruce, Trembling Aspen, and White Birch. The dominant vegetation in the Big Trout Ecoregion is coniferous forest dominated primarily by Black Spruce along with some White Spruce, Balsam Fir, and Trembling Aspen. Drier sites are typified by open stands of Jack Pine, Trembling Aspen, and White Birch with some Black and White Spruce. Low, closed and open stands of Black Spruce, Labrador Tea, Blueberry, Bog Rosemary, and Sphagnum Mosses dominate poorly drained, peat-filled depressions. More than 50% of the ecoregion is covered by wetlands. Through the baseline studies to date, approximately 190 plant species and 21 forest ecosystem types have been identified along the proposed transportation corridor. Some common understory plant species include Feathermoss, Labrador Tea, Bunchberry, Twinflower, and Velvet-leaf Blueberry. A total of 16 mammal species have been documented in the Project study area including Woodland Caribou, Moose, Wolves, Black Bear, Wolverine, Beaver, Muskrat, Snowshoe Hare, Marten, Fisher, Mink, Otter, Red Fox, and Lynx. Caribou, Moose, Marten and Beaver are the most economically important species. The regional bird surveys conducted to date have documented the presence of 76 bird species. The ten most abundant breeding bird species include the following (in order of decreasing abundance) Swainson's Thrush, Yellow-rumped Warbler, Ruby-crowned Kinglet, White-throated Sparrow, White-winged Crossbill, Hermit Thrush, Tennessee Warbler, Gray Jay, Winter Wren and Northern Waterthrush. Shorebirds observed during field studies include the Solitary Sandpiper, Semipalmated Sandpiper, Spotted Sandpiper and Greater Yellowlegs. Raptors observed in the Project study area include Bald Eagle, Osprey, Sharp-shinned Hawk, Red-tailed Hawk and the Northern Harrier. Known mammal and bird species at risk in the Project study area include Wolverine (threatened), Woodland Caribou (threatened), Bald Eagle (special concern), Canada Warbler (special concern), Common Nighthawk (special concern), Olive-sided Flycatcher (special concern), and Rusty Blackbird (special concern). We have documented the presence of all of these species in the Project study area. According to species atlas data for Ontario, the only reptile that is found in the Project study area is the Eastern Garter Snake. Also from atlas data, amphibians that likely occur in the Project study area include the American Toad, Boreal Chorus Frog, Gray Treefrog, Green Frog, Mink Frog, Northern Leopard Frog, Spotted Salamander, and the Spring Peeper. 36 of 63

45 However, it is important to note that, due to its remoteness and lack of development, the Project area has not been surveyed systematically or rigorously. Data from recent work (2010) by the Far North Terrestrial Biodiversity Project and the Far North Caribou Project in the Ring of Fire has not necessarily been entered into OMNR s NRVIS database. The absence of records in the NRVIS system should not be assumed to represent the site conditions, as it can only contain information for surveyed areas Aquatic Environment Bogs and fens are scattered throughout the James Bay Lowlands and perform numerous ecosystem functions. Wetlands provide habitat for many bird species, moose and other wildlife. A vast number of streams are present in the lowlands and connect the many shallow lakes and wetlands in the area. Westward, beyond the James Bay Lowlands, the Canadian Shield is cut by many streams and dotted by hundreds of lakes. Lakes in the lowlands range in size and depth, however, On the Shield, lakes tend to be deeper and have rocky shorelines and estuaries with abundant aquatic vegetation. Water bodies in the area support a variety of cool and cold water fish. Large rivers including the Ekwan, Muketei, Attawapiskat and Ogoki provide fish habitat important to Walleye (Sander vitreus), Lake Sturgeon (Acipenser fulvescens), Brook Trout (Salvelinus fontinalis), Lake Whitefish (Coregonus clupeaformis) and other fish species. A number of lower energy watercourses connected to these rivers provide nursery habitat for Walleye and Northern Pike (Esox lucius). Typically, Yellow Perch (Perca flavescens), White Sucker (Catostomus commersonii) and other small foraging fish species are present with these larger bodied fish. Smaller streams and lakes in the area also support a variety of smaller-bodied fish including cyprinid species, Brook Stickleback (Culaea inconstans) and Mottled Sculpin (Cottus bairdii). A number of lakes, ponds and beaver impounded watercourses surround the proposed mine site. A comprehensive surface water quality monitoring program has been implemented as part of baseline studies. In addition, a focussed aquatic baseline assessment of surface water was conducted in 2011 and included surface water and aquatic sediment quality monitoring, as well as benthic macroinvertebrate, and fish community surveys. A complementary aquatic baseline assessment of the proposed access roads, Webequie Junction, and the Savant Lake areas was also conducted in SOCIO-ECONOMIC AND CULTURAL Regional Land Use The Project is located in a region that has seen little to no development. The area includes the traditional lands of a number of First Nations and support traditional land uses including, but not limited to, hunting, trapping and fishing. Land uses in the area include recreational activities mainly consisting of tourist lodges, fly-in camps and self-directed recreational activities. Recreational land uses in the Otoskwin/Attawapiskat River Provincial Park and the Winisk River Provincial Park include water sport activities, such as rafting and canoeing. Winter roads are 37 of 63

46 present in the Project study area and join to the Northern Ontario Resource Trail (previously Highway 808) located northeast of Pickle Lake. Mineral exploration is very active in the area. Land use activities in the James Bay Lowlands Ecoregion includes hunting, trapping, and fishing, with a population of approximately 7,100. In the Big Trout Ecoregion, land uses include mining and hunting with a population of approximately 3,300. The nearest communities to the Eagle s Nest deposit are Nakina (population 700), located 300 km south southeast and Pickle Lake (population 400) located approximately 300 km west southwest. Major service centres include Thunder Bay (population 109,000), located approximately 530 km south southwest and Timmins (population 43,000) located approximately 575 km southeast Aboriginal Communities The Project lies within the James Bay Treaty or, as it is commonly referred to, Treaty 9. The site of the project lies within a region that has overlapping traditional lands. Specifically Marten Falls, Webequie and to a lesser degree Neskantaga First Nations all suggest that they have used the area from time immemorial. Other communities also suggest that their traditional lands will be impacted to some degree by the proposed mine location and all season road development. Other First Nations communities that may potentially be affected by the Project have been identified as Nibinamik, Eabametoong, Mishkeegogamang and Savant Lake and Attawapiskat First Nations. Marten Falls, Webequie, Nibinamik, Neskantaga and Eabametoong First Nations are part of the Matawa Tribal Council. Attawapiskat First Nation is a member of the Mushkegowuk Tribal Council. Brief descriptions of each of these communities, together with others that may be impacted by the Project, follow: Marten Falls First Nation is an Anishinaabe First Nation which occupies a community at Ogoki Post, approximately 130 km southwest of the Project at the junction of the Ogoki and Albany Rivers. As of February 2008, the First Nation had a total registered population of 600 people, of which their on-reserve population was 283 people. Year round access to the community is by air. A winter road is constructed each year. Noront understands that the Project is situated within the traditional lands of the Marten Falls First Nation since according to a trap line registration regime developed by the government of Ontario many community members from Marten Falls hold trap lines within the Eagle s Nest project area. Webequie First Nation is an Ojibway First Nation located approximately 80 km to the northwest of the Eagle s Nest property, on the northern peninsula of Eastwood Island on Winisk Lake, 540 km (336 mi) north of the city of Thunder Bay. Webequie is a fly-in community with no summer road access. The primary access to the community is by air to Webequie Airport or winter road, which connects to the Northern Ontario Resource Trail. In 2006, Webequie was reported to have an on reserve population of 642 people and an off 38 of 63

47 reserve population of 75. Noront understands that the project at Eagle s Nest and the infrastructure components or facilities proposed for Webequie junction are situated within the traditional lands of the Webequie First Nation. Nibinamik First Nation, also known as Summer Beaver Band, is a small Oji-Cree First Nation located on the Summer Beaver Settlement that is connected to the rest of the province by its airport, and a winter/ice road that leads to the Northern Ontario Resource Trail. In October 2009, Nibinamik First Nation had a registered population of 440 people. The community is located approximately 140 km west of the proposed Project and is accessible by air year round and by winter road. The proposed all season road corridor falls within the traditional lands of Nibinamik First Nation. Eabametoong First Nation also known as Fort Hope, is an Ojibway First Nation located on Eabamet Lake in the Albany River system, approximately 300 km northeast of Thunder Bay. It is accessible by airplane to Fort Hope Airport, by water, or by winter/ice roads, which connect the community to the Northern Ontario Resource Trail. It has the largest community population in the area with approximately 1,176 people living on reserve, and 990 people living off reserve. Fort Hope is located approximately 170 km southwest of the proposed Project. The proposed all season road corridor is located, in part, on the traditional lands of the Eabametoong First Nation. Neskantaga First Nation is an Oji-Cree First Nation also known as Lansdowne House and is located along the shores of Attawapiskat Lake, on the Attawapiskat River, approximately 130 km southwest of the Project. In 2006, Lansdowne House was reported to have an on reserve population of 274 people and an off reserve population of 99 people. The community is accessible by air year round and a winter road for a short period of time each year. Neskantaga First Nation claims the Project location falls on the traditional lands of their community. The all season road corridor is located, in part, on the traditional lands of the Neskantaga First Nation. Aroland First Nation is an Ojibway and Oji-Cree First Nation located approximately 20 km west of Nakina. It is reported to have an on reserve population of 328 people and an off reserve population of 246. Access to the community is by an all season road. Attawapiskat First Nation is a First Nation located at the mouth of the Attawapiskat River at James Bay. The on reserve population reported in the Statistics Canada 2001 Census was 1,293. The community is approximately 260 km east from the proposed Project. The proposed mine site is located in sub-watersheds of the Attawapiskat River; hence the community is downstream of the proposed project. Noront understands that Attawapiskat has indicated they have used the land located close to the project site to pursue their traditional activities. Travel to Attawapiskat is by air and by winter road. The airport operates year-round with a gravel runway. 39 of 63

48 Weenusk (Peawunuk) First Nation is a Cree First Nation community located approximately 250 km north of the proposed Project on the Winisk River. In September, 2007, the total registered population was 516. Mishkeegogamang First Nation is an Ojibway First Nation located on Highway 599, approximately 20 kilometres south of Pickle Lake. In September, 2007, its total registered population was 1,535, of which the on-reserve population was 866. Ojibway Nation of Saugeen is an Ojibway First Nation and is located approximately 20 kilometres northwest of Savant Lake. In December, 2007, its total registered population was 206, of which the on-reserve population was 72. Kasabonika Lake First Nation is an Oji-Cree First Nation located north of Sioux Lookout. Primary access to the community is through the Kasabonika Airport. A winter road is operational from January to March each year. In September, 2007, the total registered population was 914, of which the on-reserve population was 866. Métis Nation of Ontario is an aboriginal organization for the Métis population in Ontario. It is affiliated with the Métis National Council. In 1993, the Métis Nation of Ontario (MNO) was established through the will of Métis people, and Métis communities coming together throughout Ontario to create a Métis-specific governance structure. Prior to 1993, Métis had been involved in pan-aboriginal lobby groups and organizations. The Project area at Eagle s Nest is well outside the traditional harvesting lands of the Métis Nation of Ontario (MNO). However the MNO members have suggested that they could be impacted by the increased transportation delivering material to Savant Lake. Traditional land and resource use (trapping, fishing, bait harvesting, hunting, etc.) is important to the identified Aboriginal communities for economic and subsistence purposes. Land and resources are also used for cultural or spiritual purposes. Construction and operations may potentially interfere with Aboriginal participation in current use of traditional lands and resources Cultural Resources The Project is situated approximately 25 km from the Otoskwin-Attawapiskat River Provincial Park which runs the entire length of the river and includes a 200 m buffer on both sides of the river. Other parks in the region include Winisk River Provincial Park, which surrounds Webequie First Nation, Pipestone River Provincial Park and Albany River Provincial Park. Preliminary archeological studies for the mine site, Webequie Junction site, and for the proposed access corridors are underway. A Stage 1 Assessment with field inspection will be conducted in spring 2012 to identify and confirm areas of high archeological potential. A report will be submitted for approval to the Ministry of Tourism and Culture. Once the report is approved then Stage 2 subsurface testing will be conducted in the summer of of 63

49 Archaeological research in the region suggests that the area was occupied by humans as early as 7,000 years before present. These early humans, known as the Shield Archaic Culture, tended to locate themselves near caribou river crossings. Previous archaeological research has also shown that within this region primarily ungulates and fish were exploited by Aboriginal peoples from circa 1000 A.D. to contact with Europeans. Evidence also suggests that the region was intensively hunted during the historic fur trade. Previous research has indicated that the study area is located within a region that was explored by the mid-to-late 18th century. Additionally, there is a history of mining in the region spanning from the early 20th century until the present. At present there are no registered archaeological sites in the immediate vicinity of the Project. This lack of archaeological sites can be attributed to several factors, not the least of which is the overall lack of development in the area, compared to Southern Ontario. However, archaeological potential in the Project area is deemed to be moderate BASELINE STUDY PROGRAMS Baseline studies will provide benchmark conditions for assessing potential impacts to the environment, and the baseline data will be used to inform the evaluation of alternatives in selecting a final undertaking. Baseline data collected will be of the quality, depth and relevance needed to meet requirements for the EA, consistent with provincial and federal requirements. The baseline studies have been and will continue to be conducted using standard protocols and scientifically defensible methods. Where appropriate, these methods have been and will continue to be discussed with regulatory authorities. Preliminary discussions have been initiated with the Federal Department of Fisheries and Oceans (DFO), and the Provincial Ministry of Natural Resources (MNR) and Ministry of the Environment (MOE). The results and methods of the baselines studies will also be discussed with Aboriginal communities and the public. The EA will provide detailed information on the methods and approach of each baseline study. The objectives of the baseline studies are to: Describe the physical, biological and socio-economic conditions and trends in areas potentially affected by the Project in order to understand potential impacts and develop appropriate mitigation and management measures Describe the geochemical characteristics of the mineral resource extraction process and the mine wastes that will be generated by the Project in order to develop an understanding of the factors that could affect the environment Inform the selection of alternatives to minimize environmental impacts of the Project Establish benchmarks for monitoring programs that will be implemented during the construction, operation, closure and post closure phases of the Project, such that Project impacts can be iteratively addressed as necessary as the project proceeds Interact with potentially affected populations in the course of baseline data collection in order to exchange information on the Project and to provide people the opportunity to express their concerns and preferences with regard to the Project development 41 of 63

50 7.12 BASELINE CHARACTERIZATION TOOLS As project design has proceeded, a scoping study has defined the parameters of the Project and has informed the preparation of a feasibility study. Preliminary baseline studies have already been conducted for the existing environment in support of the scoping study. Studies are ongoing to provide further detail for the feasibility study phase of the Project, and to support the development of an EA that meets federal and provincial requirements. To date, baseline studies have been conducted in the field and where possible, through the review of pre-existing documentation, and have included an assessment of: Surface water quality and quantity Groundwater quality and quantity Soils and sediment type and quality Vegetation communities Wildlife communities Aquatic habitat and communities Physiography, geology and geochemistry Climate and meteorology Socio-economic conditions Cultural resources Environmental baseline studies are currently underway and scheduled to continue at the mine site, along the proposed access corridors, the Webequie Junction facilities, and the Savant Lake facility. Baseline studies currently underway include all of the components listed above and the details of the studies are provided below Surface Water Quality and Quantity Surface water quality monitoring was initiated at the mine site in A total of 11 surface water quality sites were established in proximity to the mine site and undergo seasonal sampling. In 2011, four surface water quality sites were established at Webequie Junction. Parameters include those outlined in the Mining Act and also include methyl mercury and radium 226. Sampling at these sites will continue through Water quality samples were obtained along the proposed access corridor in 2011 in conjunction with the aquatic assessments. A total of 41 water quality samples were taken along the proposed access corridor. Hydrological assessments began in 2010 within the Attawapiskat, Ekwan and Winisk watersheds. There are six hydrology stations which are located along the proposed access corridor and two located close to the mine site. Each station is equipped with a pressure sensor and data logger for continuous stage monitoring. Seasonal discharge measurements are obtained at each station. Monitoring of stream flow will continue in of 63

51 Groundwater Quality and Quantity Groundwater studies were initiated in 2010 with the installation of deep and shallow bedrock, as well as the surficial groundwater monitoring wells. At the mine site, 11 groundwater monitoring wells have been installed and are monitored seasonally. Each well is equipped with a pressure sensor and data logger to continuously record water table elevation. Response testing was conducted on each well after installation and development. Monitoring will continue during Groundwater monitoring wells were also installed at the proposed Webequie Junction site and the Savant Lake Facility in A total of seven monitoring wells were installed at the Savant Lake Facility and eight at Webequie Junction. Bedrock and overburden wells were installed at each location. Monitoring of these sites will continue in Groundwater quality sampling occurs seasonally in conjunction with surface water sampling programs. Water quality parameters include those outlined in the Mining Act and also include methyl mercury and other specialized parameters depending on the location of the well Terrestrial Baseline Studies Terrestrial baseline study programs were initiated in To date terrestrial studies have included: Breeding bird surveys Winter mammal surveys Wildlife inventories Vegetation community surveys within forest and wetland habitats Species at Risk Assessments with attention to Caribou habitat and population studies These studies have focused on defining the existing terrestrial environment at the mine site, Webequie Junction and along the proposed access corridor. Terrestrial studies are on-going and will continue in Additional data on range scale caribou values and functions, which are currently being addressed by the Ontario Far North Caribou Working Group, will be considered in the examination of transportation and mine location alternatives. The cumulative effects of other proposed linear corridors and mining developments will also be considered Aquatic Baseline Studies Fisheries assessments were initiated in 2009 at the mine site and focused on the Muketei River. During the 2010 field season, additional baseline studies were completed along the proposed access corridor. At this time investigations were focussed at identifying the fish communities and habitat within the lacustrine environments along the East-West access corridor. During 2011 comprehensive aquatic studies were completed at the mine site, Webequie Junction and at the 43 of 63

52 Savant Lake Concentrate Load-out Facility locations. The 2011 aquatic baseline program consisted of: Fish community and habitat surveys Sediment quality assessments Benthic macroinvertebrate community assessments Water Quality Assessments Additional aquatic baseline studies are planned for 2012 and include fish tissue sampling for both sport and forage species in proximity to the mine site and along the proposed access corridor Physiography, Geology and Geochemistry Geological surveys have been on-going since the original discovery of the deposit. Additional physiographical and geological investigations are currently on-going at the mine site, Webequie Junction and the Savant Lake Concentrate Load-out facility. Additional studies are planned to occur along the proposed access corridor. In respects to geochemistry, further acid rock drainage (ARD) and metal leaching (ML) investigations will take place within ore, overburden and aggregate materials at the mine site. Further ARD and ML investigations will also occur once a preferred access route is identified and aggregate sources are identified Climate and Meteorology A meteorological station was installed near the proposed mine site in Temperature, air pressure, wind speed and direction, rainfall, incoming shortwave radiation, and relative humidity are measured hourly by a HOBO U30 Logger located on the Koper Lake meteorological station. Long term climate data have been compiled from Environment Canada weather stations in the regional study area. Meteorological data collection is ongoing Socio-economic Baselines Studies Noront has been and will continue to collect data on the socio-economic environment through the consultation with community members, the review of existing published and unpublished data and government databases Cultural Resources In 2010 Woodland Heritage Services Ltd. conducted a stage 1 archaeological assessment along the proposed access corridors and at the mine site. Further assessments including stage 2 assessments at sites of high archaeological potential identified during the stage 1 assessment are scheduled to occur once the proposed project footprint has been defined. 44 of 63

53 7.13 POTENTIAL EFFECTS OF THE PROJECT A preliminary, non-inclusive list of potential effects of the Project on the environment are identified in the following sections It is expected that a broader and more detailed range of potential effects will be identified when alternatives are selected, as baseline studies are completed and through consultation with the public, Aboriginal communities and government reviewers. An example of potential effects which may require more detailed investigation include the development of preferential pathways for wildlife movement from utility and infrastructure corridors, and the increased human access to remote areas Mine Development and Operation Loss or fragmentation of terrestrial habitat due to development of mine site facilities Dust, fumes and lighting from the mining operation and handling and transport of the concentrate. This will be minimized by having most of the operations occur underground. Noise from the operation of heavy machinery. Pumping of mine water to surface water courses which could affect local water quality if groundwater quality differs substantially from surface water quality. All mine water will be re-used by the underground mill. However, in the event that mine water that cannot be re-used, it will be treated and discharged into naturally filtering wetlands. Seepage to soils and groundwater and runoff to surface water from temporary waste rock piles/aggregate piles during initial mine development. However, the temporary stockpiles will be stored on pads to capture and treat runoff. Seepage to soils and groundwater and runoff to surface water from aggregate piles and settling ponds during mine development and operations Fuel or chemical spills at the mine site Concentrate or chemical spills at the mine site Increased human interaction with wildlife Water Management Systems Residues and suspended materials from on-site ditches, wash areas, and maintenance facilities could affect water quality in receiving waters, to be mitigated by stormwater management and treatment Drawdown of groundwater through development of the mine and associated facilities. However, the deep bedrock has a low hydraulic conductivity. The overburden and shallow groundwater aquifers will be isolated from mine operations. Potential impact to wetlands, peat and water movement due to the drawdown of groundwater Power Generation Noise, air quality and lighting impacts from operation of diesel generators at the Webequie Junction site and the back-up power generator at the mine site Disruption of habitat during the construction of the power line transmission corridor Disruption, loss and fragmentation of habitat during the construction and maintenance of the transmission line 45 of 63

54 Transfer Facility Development and Operation Noise and dust generation from operation of heavy equipment Concentrate slurry spills Seepage to soils and groundwater and runoff to surface water from the sedimentation pond and concentrate stockpiles Dust and fumes from handling of the concentrate Access Road Corridor Development and Operation Loss or fragmentation of terrestrial and aquatic habitat due to development of roads and pipeline corridors Disturbance and/or fragmentation of wildlife habitat during construction of access corridors Dust, fumes and lighting from the transport of the ore concentrate on the all-season road corridor Potential increased erosion and sedimentation of waterbodies from road runoff, to be mitigated by stormwater management, including proper ditching Increased access to resources including fishing, hunting and aggregates Potential impacts related to the extraction of aggregate materials Increased access to wilderness areas and provincial parks which could lead to: o Increased traffic and use of the parks (snowmobile/atv) o Increased fishing pressure within the park o Effects on existing recreational features Potential impacts to stream morphology and flows Airstrip Loss or fragmentation of terrestrial habitat due to development of the airstrip Noise from the operation of aircraft Dust from the operation of a gravel runway Waste Management Systems Potential effects on surface water quality from fuelling and servicing areas, mitigated by collection of water to storm water system, and treatment of storm water Domestic water, mitigated by sewage treatment prior to discharge Seepage to soils and groundwater and runoff to surface water from solid waste storage areas Potential Socio-Economic Effects of Mine Operation Increased employment and procurement of goods and services Effects on current use of traditional lands and resources by Aboriginal people Minimal visual impact on the area of the mine site and associated infrastructure Changes in the dynamics of tourism and recreational activities 46 of 63

55 Effects on traditional land use activities such as, hunting, fishing, trapping and harvesting Potential effects on archaeological, heritage and cultural resources 7.14 CUMULATIVE ENVIRONMENTAL EFFECTS Noront will identify and assess the cumulative environmental effects of the Project, including on site and off site components, in combination with other past, present or future projects that are certain or reasonably foreseeable projects and/or activities. If applicable, this may include: future mines, transportation alternatives (road vs. rail corridors), hydroelectric generation, transmission and any other projects or activities. Cumulative effects may result if: Implementation of the project causes direct residual negative effects on the environmental components, taking into account the application of technically and economically feasible mitigation measures The same environmental components are affected by other past, present or reasonably foreseeable future projects or activities Environmental components that would not have an adverse effect from the Project can, therefore, be omitted from the cumulative effects assessment. A cumulative effect on an environmental component may, however, be important even if the assessment of the Project s effects on this component reveals that the effects of the Project are minor. The EA will describe the analysis of the total cumulative effect on a VEC over the life of the Project, including the incremental contribution of all current and proposed projects or activities, in addition to that of the Project. The EA shall include different forms of effects (e.g., synergistic, additive, induced, spatial or temporal) and identify impact pathways and trends. 47 of 63

56 SECTION ASSESSMENT AND EVALUATION OF THE ALTERNATIVES In order to evaluate project alternatives it will be necessary to establish criteria, indicators and evaluation methods. The criteria are designed to assess the effects of the undertaking and alternatives and the undertaking on the environment. In addition, each criterion will have one or more indicators that will identify how the potential environmental effects will be measured. The proposed evaluation criteria and indicators that will be used for assessing the alternatives in the EA include but are not limited to those outlined in Table 8.1. Table 8.1 also indicates the potential data sources for the criteria and indicators. 8.1 EVALUATION METHODS In order to ensure that the alternatives are evaluated in a clear, logical and traceable fashion the information generated through the following analyses will be summarized in a series of tables and elaborated on within the text of the EA Net Effect Analysis The first evaluation method is a net effects analysis which will evaluate the alternatives to and the alternative methods of carrying out the undertaking. The net effects analysis will be done in consultation with government agencies, Aboriginal groups and the public, and will consist of the following steps: 1. Development of evaluation criteria and indicators based on the proposed undertaking, existing environmental conditions, range of alternatives to be considered and type and scale of potential environmental effects and their relative significance. 2. Application of evaluation criteria and indicators to each alternative to identify the potential effects on the environment. 3. Development of appropriate avoidance, mitigation and compensation measures based on current procedures, historical performance and existing environmental conditions. 4. Application of the avoidance, mitigation and/or compensation measures to identified potential effects in order to identify the net effects on the environment. The evaluation criteria and indicators are presented in Table 8.1, however, they will be further refined during the EA process and documented in the final EA. The assessment of environmental effects will increase in detail as the preferred alternatives are identified Comparative Evaluation - Reasoned Argument Following the completion of the net effects analysis the alternatives will be compared through a Reasoned Argument method to identify the preferred alternative. The reasoned argument method highlights the relative advantage and disadvantage of each alternative based on its identified net effects. As a result, the relative differences and key impacts of each alternative for 48 of 63

57 each factor/environmental component will be understood and examined to provide a clear rationale for the selection of a preferred alternative. 8.2 IMPACT ASSESSMENT Natural Environment While the impact assessment will include predictions of changes to physical environmental components, the focus of determination of significance is generally based on the biological receptors that are subject to those changes. Numerical guidelines are readily available for many physical parameters such as water and air quality, however, the significance of any exceedance lies in determination of the effects on, or risks to, biological receptors. Consequently, the environmental impact assessment will also address biological resources. Many of the pathways of effects relate to changes in the physical environmental components listed above. Potential impacts may also arise from direct project-related activities. For example, site clearing may physically displace or alter habitat, and project development may incur indirect socio-economic factors such as increased human population density, and improved access that can result in changes in exploitation of local biological resources. Biological components of the environment generally include: Aquatic habitat (e.g., creeks and rivers) Aquatic biota (e.g., algae, plants, invertebrates and fish) Terrestrial habitat (e.g., forests, grasslands, wetlands, riparian corridors) Terrestrial biota (e.g., plants, and wildlife including amphibians, reptiles, birds and mammals) Wolf-caribou and bear-caribou predator prey relationships, caribou behavioural responses, habitat losses and impacts, and caribou migration routes Taken together, the physical and biological impact assessments include the natural environmental impact assessment, and are used to predict any changes to the quality and availability (quantity) of resources in the study area. The assessment process evaluates both the potential impacts of the Project, and the Project s alternatives. The process of assessing and evaluating the positive and negative impacts of the Project, as conducted in the following sections, is based on an integration of a number of criteria and sources of information. The process includes 1) an evaluation of site-specific information, in the form of empirical data from the site, modelling studies, and consultation with stakeholders and regulators, and 2) a review of the broader technical and scientific literature. The latter includes any published scientific literature, impact assessments and environmental effects studies at similar sites, published Best Management Practices and professional judgment and experience. 49 of 63

58 Determination of the Significance of an Impact The determination of the significance of an impact is often assessed relative to existing criteria, for example regulatory guidelines. As a result, physical components, such as air quality, surface water and groundwater quality, and soils and sediment quality are assessed with respect to the environmental standards applicable to the undertaking. Environmental standards/criteria applicable to the Project will include provincial and federal criteria, standards, and/or guidelines for air, noise, water, soil, sediments and biota. The levels of significance of effects of these components will be one of the following: Low: Predicted concentrations are below applicable standards. Moderate: Exceedance of standards, up to 10-times the standard (to account for safety factors that are usually built into these standards). High: Predicted concentrations are more that 10-times the applicable standards. Exceedance of a regulatory criterion is not necessarily a significant effect in itself, and it does not automatically provide a measure of significance to biological receptors. Each environmental change must be interpreted according to the degree of risk of impact to the biological communities. This evaluation will be based on specific attributes of pathway, exposure and receptor characteristics, as well as the likelihood of measurable effects on populations or communities. This approach recognizes that effects at the community or population level can have much longer lasting impacts than effects on individuals. Therefore, the levels of significance of effects on biological communities will be assessed on the basis of the following: Low: Effects are limited to a few individuals, usually in the immediate vicinity of the impact, and are not expected to result in population-level changes. Moderate: Population-level changes may occur, but are not expected to be beyond the normal range of fluctuations of population size or density for those species. Populations are expected to possess compensatory responses sufficient to recover from these changes. High: Population-level changes may occur that are expected to result in changes in population size or density beyond the normal range of fluctuations for those species. It is uncertain whether populations would possess compensatory responses sufficient to recover from these changes. The determination of significance is based on the potential impacts on biological receptors, rather than the physical environment. Since the effects on physical components, such as water quality, are determined with respect to their potential biological effects (e.g., water quality guidelines that have been developed with the purpose of protecting biological resources). Hence, the assessment of significance is considered within this context. 50 of 63

59 With respect to caribou, it is not necessary for the animals to be present or close by for there to be cumulative negative impacts. While the ultimate effects occur to individuals and will be measured as impacts to populations, the proximate effects and measures are often related directly to the physical environment as indicators of potential impacts. For example, the location and density of linear features are important indicators and will be assessed at the sub-range and range scales. Where potentially significant impacts to the environment are identified, additional mitigation measures will be incorporated, where feasible, to minimize the residual impacts, which will then re-evaluated to determine the final significance of the likely impact. However, avoidance or prevention of negative impacts will be the priority. The assessment will be conducted with the use of tables that organize and summarize the process described above into comparable and intuitive presentations for each of the Project phases. The significance of the predicted changes in the environment will be assessed relative to measurement criteria. The assessment of significance will be conducted in consideration of different assessment categories that are used to predict the magnitude and likelihood of an effect. The categories to be considered are: Direction: Whether a potential impact will be positive, neutral or negative. Geographic Extent: The area over which an impact will be experienced. Duration: The period of time over which an impact occurs. Frequency: How often an impact occurs within a given time period. Reversibility: The potential for recovery from an impact to a level similar to baseline conditions. Magnitude: Describes the results of an impact in a measurable way by means of specific criteria (e.g., area of habitat lost, density or numbers of species affected), relative to the baseline condition and to relevant provincial or federal standards, guidelines, or criteria Socio-economic/Cultural Environment Potential effects of the Project on the social, economic, and cultural environment and to human health will be assessed. These will include the effects of improved transportation and the provision of employment opportunities on the local communities and First Nations. The social, economic, and cultural impact assessment will measure both the positive, negative, direct and indirect effects of the Project on individuals, organizations, communities and governments. Information on any predicted social, economic and/or cultural benefits of the Project will be considered through an analysis of the advantages and disadvantages of the Project. This information will be reviewed by the public, Aboriginal communities and government reviewers before a decision is made by the Minister of the Environment in assessing the justifiability of any significant adverse environmental effects. 51 of 63

60 The principles outlined regarding establishing baseline conditions will be applied to the assessment of potential effects on social, economic and cultural issues. With respect to socio cultural and socio-economic conditions, Noront will clearly identify which social, economic and cultural issues relate directly to changes the Project may cause in the environment Determination of the significance of an Impact Impact assessment methodology for the Socio-economic Impact Assessment (SIA) is described in this section. As with environmental impacts, socio-economic impacts will also take into consideration construction, operations and closure stages of the Project. Social impact assessment takes into consideration the socio-economic components of the environment, including: Politics and governance Economics Demographics and people Health Social maladies Education Land tenure and use Infrastructure Cultural Heritage and archaeology Indigenous peoples or ethnic minorities The SIA will be focused on identifying potential impacts to First Nation communities with special consideration with respect to the potential impacts to sites of aboriginal cultural significance and traditional land use areas. The evaluation method, and the confirmation of what elements will be studied, will be confirmed through consultation with Aboriginal communities, the public and government reviewers. Evaluation Methods The key steps in developing the socio-economic elements impact assessment are described below: Socio-economic baseline: The basis of social analysis is the socio-economic baseline, which is complemented by consultation and discussion with those who may be affected by the Project. Information collected during the baseline study and consultation is used to identify factors that may be influencing the human environment prior to Project implementation Review of Project activities: Project activities that may affect the social or economic characteristics of local communities are identified 52 of 63

61 Key Issue Identification: Key social and economic issues identified during the scoping phase of the EA are revised and considered with the final Project activity details. The purpose is to identify the essential issues for the Project within the overall social, political and cultural context described in the baseline Impact Categories: The key issues are used to develop a set of impact categories that form the basis of the impact assessment. Each impact category may have a set of sub-category topics that address elements of the IFC Performance Standards and other international guidelines or issues raised during consultation Mitigation: Actions are developed to avoid or minimize negative impacts and maximize benefits. The interventions to minimize negative impacts and maximize positive impacts make up the social elements of the Environmental and Social Management Plan Residual Impacts: Residual impacts, also referred to as social significance, are the impacts predicted to occur after mitigation. The impact assessment is performed on residual impacts Evaluation Indicators Determination of socio-economic impact follows a different methodology than the one used for physical and biological impacts. There are, however, some similarities in the definition of attributes. The four attributes applied to the determination of socio-economic impact significance are listed and defined below: Direction: Indicates whether the impact is positive, negative or neutral. Some impacts may have both positive and negative dimensions Magnitude: Indicates the degree of change in a socio-economic parameter and is generally a qualitative assessment Geographic extent: Indicates the geographic and administrative units that will be impacted. Some impacts may affect only individuals, whereas others may affect the Local Study Area (LSA), Regional Study Area (RSA) or the entire country Duration: Indicates the length of time over which an impact may occur. Duration is usually related to the description of the Project Unlike environmental impacts, social impacts will not be assessed on probability. Socio-economic impacts are part of an ongoing process of interdependent economic and social change. Although there are isolated exceptions, most socio-economic impacts are experienced continuously by people. Thus, probability is not often a useful attribute for significance assessment, and so social impacts will be assessed by consultation with potentially affected communities. 53 of 63

62 SECTION POTENTIAL MITIGATION MEASURES Mitigation measures will be proposed where a Project activity may have an adverse effect on the environment and it is not possible to avoid or prevent the adverse effect. In many cases, the Project activities described include mitigation measures, with the result that these activities typically do not result in adverse effects. Where additional mitigation measures are warranted, these will be proposed. Where additional mitigation measures are identified, a second assessment will be undertaken to determine the potential significance of the impact with the mitigation measures applied. Technical and feasible measures investigated to mitigate the Project s potential adverse environmental effects will be documented within the EA. These measures will be presented in a fashion that will give clarity and definition to the mitigating measures taken. Mitigation will be carried out through the use of contracts, regulations and other instruments as needed. 54 of 63

63 SECTION COMMITMENTS AND MONITORING During the EA, a monitoring framework will be developed for the post-ea phase, to address the pre-construction, construction, operation and closure phases of the Project. It will include compliance and effects monitoring and will include the schedule and frequency of the proposed monitoring plans and methods. Any follow-up programs will also be indicated. The EA will include a list or table of commitments made by Noront during the ToR process, and where or how they have been addressed in the EA document. The EA will also include a list or table of any commitments made by Noront during the preparation of the EA. These include commitments relating to additional studies to be carried out, monitoring, public consultation and contingency planning, impact management measures (i.e. mitigation measures), as well as documentation and correspondence MONITORING PLANS Based on the environmental and socio-economic impact assessment, the EA will outline two impact management plans, an Environmental Management Plan (EMP), and a Social Management Plan (SMP). An Environmental and Social Monitoring Plan will be developed as part of the EA to address specific monitoring requirements. These will be focused on those components where there is potential for effects from Project activities. The Monitoring Plans will include compliance and effects monitoring, and will be used to verify the predictions of the impact assessment, and where required, for the development of adaptive management strategies to address any unforeseen effects, especially unforeseen cumulative effects. These plans will: Provide a comprehensive list of commitments made by Noront during the ToR process, and detail where or how they have been dealt with in the EA Provide a list of commitments made during the preparation of the EA Reflect the results of consultations and be predicated on an on-going program of consultations over the life of the Project Include compliance and effects monitoring Describe the mitigation and benefit enhancement measures that will be put in place to address significant residual Project impacts specific to each of the construction, operations, closure and post closure phases Describe the monitoring of impact mitigation and benefit enhancement measures Describe how the implementation of mitigation and benefit enhancement measures will be managed to ensure success. This will take into account institutional capability to participate in management of the Project`s environmental and social performance where such participation is deemed appropriate. Present monitoring costs, schedules and frameworks, as developed during the preparation of the EA 55 of 63

64 Environmental Management Plan The objective of the Environmental Management Plan (EMP) is to set out clearly the key components of environmental management for the Project and thereby ensure that the following concepts are realized throughout the construction, operation, closure and post-closure phases of the Project: Negative impacts on the physical and biological environments are mitigated if avoidance and prevention are not possible Benefits that will arise from the development of the Project are enhanced Compliance with existing legislation and consistency with provincial guidelines and best practice Compliance with Project permits and approvals The EMP will address: Management of physical environment Management of biological environment Emergency preparedness and response Contingency planning Health and safety Closure and post closure Management plan implementation For each of the above referenced subject areas, the EMP will identify policies, practices and/or procedures, including monitoring, inspections and audits, which will contribute to the mitigation of any potential environmental impacts. Mitigation could involve selecting alternatives for particular Project components that reduce the potential for negative impacts and including techniques and procedures to reduce the overall impact significance. In addressing emergency preparedness and response, the EMP will identify the principal environmental risks associated with the Project, evaluate each risk qualitatively and propose measures to minimize the potential for occurrence, and in the event of occurrence, to minimize the potential for negative effects. In addressing closure and post closure, the EMP will set out objectives and propose measures, including contingency measures, for achieving those objectives. In addition, the EMP will address progressive rehabilitation, describe expected post closure conditions and propose post closure monitoring Social Management Plan The Social Management Plan will address the avoidance of, minimization of, and/or compensation for any negative socio-economic effects that could result from the Project. It will 56 of 63

65 also address the enhancement of any positive benefits that could result. Mitigation and enhancement could involve: Selecting alternatives for particular Project components that reduce the potential for negative impact Developing Project practices and procedures that reduce the potential for negative impact and/or enhance the potential for benefit Identifying social impacts and benefits that can be directly mitigated and/or enhanced, developing specific measures that address those impacts and benefits Identifying other social impacts that are difficult to completely mitigate, such as changes resulting from migration, and developing broad measures that contribute to the quality of life of the affected populations The Social Management Plan will also set out the monitoring required to ensure that identified mitigation and benefit enhancement measures are implemented and that identified objectives are achieved. The monitoring will facilitate the adaptive management of socio-economic effects, many of which are inherently unpredictable. Indicators of the achievement of objectives will be identified and these will become the parameters to be monitored. In practice, the monitoring will be based both on ongoing data collection and consultations, and will also use any secondary data sources that might be available. 57 of 63

66 SECTION CONSULTATION PLAN AND CONSULTATION TO DATE 11.1 CONSULTATION PLAN FOR THE ENVIRONMENTAL ASSESSMENT Introduction Consultation is a central objective of the provincial EA process. Consultation planning was undertaken with consideration of the MOE Codes of Practice on Preparing and Reviewing the Terms of Reference for Environmental Assessments in Ontario (2009) and Consultation in Ontario s Environmental Assessment Process (2007). A detailed Consultation Plan is provided in Appendix A. The following provides a summary of the key elements and objectives of the Consultation Plan. The following elements of a successful Consultation Plan, as suggested by the MOE, have been included in the Consultation Plan: Clear Objectives Stakeholder Identification Consultation Methods Issue Identification Integration of Input Proponent Evaluation of Consultation Objectives As outlined in The Code of Practice: Consultation in Ontario s Environmental Process (2007), a consultation plan must: Indicate how potentially interested and affected persons, including Aboriginal peoples, will be identified, notified and consulted Indicate how government agencies will be identified, notified and consulted Identify the points in the environmental assessment process when interested persons will be consulted Identify the decisions that interested persons can provide input to and what role they can play when the proponent makes choices Acknowledge and attempt to address concerns raised during the environmental assessment process In addition, as stated in The Code of Practice: Preparing and Reviewing Terms of Reference for Environmental Assessments in Ontario (2009), the consultation plan should outline: The general consultation methods proposed How input from interested persons will be obtained A description of key decision-making milestones during the preparation of the environmental assessment when consultation will occur Issue resolution strategy 58 of 63

67 Based on the above requirements the objectives of the consultation plan are to outline: Key stakeholders and the process by which they are identified The consultation strategy including the consultation methods that will be used to involve stakeholders in the EA process, how Noront will provide access to information and how feedback on the Project will be provided The consultation phases in the preparation and review of the EA and the key points in the EA process when consultation will occur How Noront will document and address concerns that are raised during the EA process 11.2 CONSULTATION TO DATE The initial consultation strategy for the Project was to proactively meet with government agencies, stakeholders and Aboriginal groups to share information and receive feedback about the Project. A summary of the pre-ea consultation phase activities is provided in the following sections. An overview of the preliminary list of issue categories and subjects is provided in Table This pre-ea phase of consultation was followed by consultation related to the development of the ToR. Details of the consultations activities that occurred during the development of the ToR are provided in the Record of Consultation PRE-EA CONSULTATION ACTIVITIES Public Consultation activities with the public included written information sharing, videos, face-to-face meetings, community events and website updates. A website developed by Noront called Mikawaa (Discovery in Oji-Cree) allows interactive online discussion with community members. Noront has also created a Project website and updates the company website A monthly radio program is transmitted through Wawatay Radio to discuss various aspects of the Project Description in Oji-Cree. Wawatay Radio reaches most communities by FM, Bell Express View and on the internet Municipal Information meetings have been undertaken with municipal leaders and Open House sessions in the communities of Pickle Lake and the City of Thunder Bay. Less formal meetings have also taken place with Greenstone, Pickle Lake and Thunder Bay Provincial and Federal Government A series of meetings and presentations have taken place with Provincial and Federal government agencies, and Project reports and memos have been distributed for review and comment. Discussion with government agencies has focused on the EA permitting and approval process and schedule, tailings management, and baseline studies. 59 of 63

68 Aboriginal Engagement Aboriginal Engagement on the Project was initiated in Engagement meetings were initiated in 2010 with Marten Falls and Webequie First Nations. The meetings were to build on existing relationships, actively sharing information and seeking feedback from Aboriginal communities. Completed activities related to issues scoping and the ToR include a series of presentations providing an overview of the Project, discussions with trap line holders in the Project area, hiring of First Nations field guides and sponsorship of community based programs to foster interest in mining for school aged children and adults. Communication and feedback have been initiated through phone calls, letters, and s. Table 11.2 provides a summary of Aboriginal engagement meetings Participation of Métis Communities Initial efforts were made in 2010 to contact Métis groups in the Geraldton region. Other contacts had been made to the headquarters of the Métis Nation of Ontario to help Noront identify individuals for follow-up contact. In October 2010, the Métis expressed an interest to Noront regarding the Project. In June 2011, Noront met with the Métis Nation of Ontario lands and resources director. Phone meetings and a face-to-face meeting occurred during the summer of 2011 with plans to determine additional meetings with potentially affected MNO groups. After further discussions, the project location was considered outside the region where Métis Nation of Ontario members practice their traditional hunting activities Issues and Concerns Previously identified issues and concerns include: Business, employment and training opportunities Completion of Project open houses in the community Environmental concerns, including route and exploration activity Social concerns in regards to demands on community infrastructure Impact to traditional territory from Project development Presentation of Project updates to community members to ensure meaningful engagements ATK studies All-season road development Slurry pipeline Table 11.3 provides a preliminary summary of the issues and concerns that have been raised during initial engagement with First Nation communities. 60 of 63

69 SECTION FLEXIBILITY TO ACCOMMODATE NEW CIRCUMSTANCES It is recognized that circumstances may arise that could prevent the commitments made in the ToR from occurring. In addition, the project description presented in the ToR is preliminary and the proposed activities presented may change as additional studies are completed during the EA process. Flexibility has been incorporated into the ToR to accommodate new circumstances that may arise during the EA process. The content of the EA may be refined, where appropriate, to reflect the input gathered through studies and received through consultation and engagement. As such, it is possible for that minor variations to the ToR will occur without the need to re-start the EA process. However, any proposed modifications to the ToR will be discussed with the MOE prior to being implemented. 61 of 63

70 SECTION OTHER APPROVALS REQUIRED The development of the Eagle s Nest Project, as indicated in Section 1, is subject to the OEAA and the CEAA as well as the Far North Act. The development of the Eagle s Nest Project will also requires a variety of additional federal, provincial and municipal permits and approvals. A preliminary list of the anticipated licences, permits and approvals that may be required prior to mineral development and/or construction activities is provided in Table Table 13.2 provides a preliminary list of guidelines, criteria, objectives and standards that may apply to the Project. This table will be updated during the EA. 62 of 63

71

72 TABLE 6.1 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT TERMS OF REFERENCE PRELIMINARY LIST OF ALTERNATIVES TO Print Mar/28/12 13:50:24 Component Alternatives To To be Considered in the EA Eagle's Nest Project ``Do Nothing`` Yes Production Rate Transportation Corridor (Site Access) Airstrip Concentrate Shipping Webequie Junction Facility Savant Lake Concentrate Transfer Facility Power Generation Tailings Management Waste Management (Savant Lake, Mine Site and Webequie Junction) Equal to 2960 t/d Less than 2960 t/d Greater than 2960 t/d "Do Nothing" Winter Road Railway Hovercraft Aircraft All Season Road "Do Nothing" Access Mine Site via Ground Transport "Do Nothing" Pipeline Railway Road Haulage "Do Nothing" "Do Nothing" Road Haulage "Do Nothing" Diesel-Fuelled Power Generation Plant Hydroelectric Solar Natural Gas Transmission Line (connecting to the existing electrical grid) Wind "Do Nothing" Underground Disposal Surface Disposal "Do Nothing" Incinerator Onsite Landfill Shipping to Off-site licenced landfill Yes Yes Yes Yes Yes No No No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No No No Yes No Yes Yes Yes Yes Yes Yes Yes I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Tables\[Table 6.1 and alternatives.xlsx]table MAR'12 ISSUED WITH REPORT JSP ALR SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D Page 1 of 1

73 TABLE 6.2 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT TERMS OF REFERENCE PRELIMINARY LIST OF ALTERNATIVE METHODS Print Mar/28/12 13:50:24 Component Alternatives Methods To Be Considered in the EA Mining Methodology Underground Mine Open Pit Mine Yes No Location of infrastructure including accommodations complex, site roads, fuel storage, explosives factory, portal, piles and stockpiles Yes Mine Site Infrastructure Location of mill, warehouse, and shops underground Location of mill, warehouse and shops on surface Location of Processing and Milling Facilities Yes Yes Yes Waste Rock Handling and Storage Underground storage Above ground storage Yes Yes Cemented Underground Storage Yes Tailings Handling and Storage Un-cemented Underground Storage Lined above ground storage Yes Yes Unlined above ground storage Yes Webequie Junction Savant Lake Transfer Facility Water sources for process and potable supplies Location of Webequie Junction Facility Location of infrastructure including access road Location of the facility Placement of Infrastructure including access road Intake Locations Groundwater or surface water sources No Yes No Yes Yes Yes Effluent Discharge Location of discharge at the mine site, Webequie Junction and the Savant Lake Concentrate Load-out Facility Yes Sewage Treatment Systems/Facilities Type of sewage system/facility at the mine site, Webequie Junction and Savant Lake Concentrate Transfer Facility Yes Location of system/facility Yes Waste Management Facility Location of waste management facilities at Webequie Junction, Savant Lake Concentrate Transfer Facility and the mine site Yes Mine water Management, Treatment, and disposal Power Supply Selection of licenced landfill Water storage locations Discharge Locations Location of the Power Plant at Webequie Junction or the Mine Site Yes Yes Yes Yes Transmission Line from Webequie Junction Route selection Yes Transportation Corridor (Site Access) Winter Road Option All-season Road Option East-West corridor North-South Corridor Alignments Construction Methods Yes Yes Yes No Yes Yes Aggregate Sources Location of aggregate source Yes Concentrate Pipeline Route Selection Pipe material Construction Methods Yes Yes Yes I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Tables\[Table 6.1 and alternatives.xlsx]table MAR'12 ISSUED WITH REPORT JSP ALR SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D Page 1 of 1

74 TABLE 8.1 NORONT RESOURCES LTD. EAGLE`S NEST PROJECT TERMS OF REFERENCE PRELIMINARY LIST OF EVALUATION CRITERIA, INDICATORS AND POTENTIAL DATA SOURCES Factor/Environment Proposed Criteria Indicators Potential Data Sources Print Mar/28/12 13:51:42 Baseline studies completed in the vicinity of the proposed undertaking including site surface water and drainage studies Ongoing site monitoring reports Surface Water Quality Comparison with available objectives/guidelines/standards Potential for change from baseline conditions Surface water quality assessment Government data sources including field studies, guidelines and published water quality information Results of geochemistry studies (i.e. ARD and ML assessment) Published and unpublished data sources including technical papers and reports Proposed design of the undertaking Surface Water Quantity Groundwater Quality Potential for change from baseline conditions Potential to change from baseline conditions Comparison with available objectives/guidelines/standards Baseline studies completed in the vicinity of the proposed undertaking including site surface water and drainage studies Ongoing site monitoring reports Topographic Maps Government data sources including published groundwater quantity data and guidelines Various GIS data sources including Land Information Ontario, satellite imagery and aerial photography Published and unpublished data sources including topographic and other mapping, technical papers and reports Proposed design of the undertaking Baseline studies completed in the vicinity of the proposed undertaking including site geological and hydrogeological investigations Ongoing site monitoring reports Groundwater quality assessments Regional information on groundwater quality Published and unpublished data sources including, technical papers and reports Proposed design of the undertaking Groundwater quantity Potential for change from baseline conditions Baseline hydrogeological studies including the installation of surficial and bedrock monitoring wells Changes to groundwater functions in relation to recharge and discharge and aquatic/wetland habitat Geophysical investigations including ground penetrating radar surveys utilization of models to developed water balances to determine flow calculations Direct loss of habitat functions Proposed design of the undertaking Natural Environment Terrestrial Environment Habitat fragmentation, disruption and destruction Indirect loss of wildlife habitat Impact on Species at Risk Effects on forest cover Effects on biodiversity Effects on ecosystem integrity Effects on ecological connectivity Loss of soils Baseline studies completed in the vicinity of the proposed undertaking (wildlife surveys, inventories, Land Classification) Published and unpublished data sources Government data sources and databases including field data and published and unpublished data through the data sharing agreement Various GIS data sources including Land Information Ontario, satellite imagery and aerial photography ATK studies Consultation with aboriginal, public and government Aquatic Environment Occurrence of wildlife-vehicle accidents Direct loss of aquatic habitat through the harmful alteration, disruption or Proposed design of the undertaking destruction of habitat Indirect loss of aquatic habitat and functions through sedimentation and dewatering Published and unpublished data sources Direct loss of aquatic species Indirect loss of aquatic species Impact on Species at Risk Changes to surface water quality and quantity ATK studies Changes to sediment quality Consultation with aboriginal, public and government Direct and indirect loss of riparian habitat Baseline studies completed in the vicinity of the proposed undertaking (wildlife surveys, inventories, Land Classification) Government data sources and databases including standards, objectives and guidelines field data and published and unpublished data through the data sharing agreement Various GIS data sources including Land Information Ontario, satellite imagery and aerial photography Number of watercourses/water bodies in the study area Atmospheric Environment Acoustic Environment Potential to change from existing conditions Compliance with regulatory standards Potential to change from existing conditions Compliance with regulatory standards Proximity of receptors Regional air quality data Interpolation based on existing data Onsite and local meteorological monitoring Proposed design of the undertaking and operation data Government data sources and databases Published and unpublished data sources Emissions summary and air quality dispersion assessment Noise monitoring in the vicinity of the undertaking Interpolation based on available data Acoustic assessment and modeling Proposed characteristics of the undertaking and operation data Page 1 of 2

75 TABLE 8.1 NORONT RESOURCES LTD. EAGLE`S NEST PROJECT TERMS OF REFERENCE PRELIMINARY LIST OF EVALUATION CRITERIA, INDICATORS AND POTENTIAL DATA SOURCES Print Mar/28/12 13:51:42 Factor/Environment Proposed Criteria Indicators Potential Data Sources Determination of archeological potential by conducting a Stage 1 archaeological assessment Stage 2 archaeological assessment conducted in areas of high archaeological potential Archaeological Resources Presence of known archaeological resources Potential effects on areas on archaeological potential Published and unpublished documentation Government data sources including archaeological site data base Consultation with Aboriginal groups and Stakeholders Cultural Environment Physical and Cultural Heritage Resources Proposed design of the undertaking Published and unpublished documentation Presence of built heritage resources or cultural heritage landscapes Consultation with Aboriginal groups and other stakeholders Presence of designated, commemorated, inventoried, and identified built Site analysis and survey of cultural heritage resources located within the proposed study area heritage resources and cultural heritage landscapes in proximity to the proposed undertaking. Relevant studies that have surveyed cultural resources in the area Potential effects on above ground cultural heritage resources. Effects can Government data sources include direct and indirect impacts. Proposed design of the undertaking Aboriginal Interest and Land and Resource Use Potential direct and indirect effects on past, current and planned tradition land and resource use ATK studies Consultation with Aboriginal groups and government Existing published and unpublished documentation Consultation with Aboriginal groups and government Outdoor Recreation and Tourism Potential indirect and direct effects on outdoor recreation and tourism in the vicinity of the undertaking Existing published and unpublished data sources Baseline study reports Consultation with Aboriginal groups and government Hunting, Trapping and Guiding Potential indirect and direct effects on hunting, trapping and guiding industry Existing published and unpublished data sources Baseline study reports Socio-economic Environment Fishing Potential to effect the commercial, recreational and subsistence lake and stream fisheries Consultation with Aboriginal groups and government Existing published and unpublished data sources Baseline study reports ATK studies Potential to directly or indirectly effect the use of navigable waters Existing published and unpublished data sources Navigable Waters Potential to change from baseline conditions Baseline studies conducted within the vicinity of the undertaking Potential to directly and indirectly effect human health Various GIS data sources including Land Information Ontario, satellite imagery and aerial photography Baseline studies Human Health Potential to change from baseline conditions Government data sources and databases Published and unpublished documentation I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Tables\[Table 8.1 Criteria and Indicators.xlsx]Table MAR'12 ISSUED WITH REPORT JSP ALR SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D Page 2 of 2

76 TABLE 11.1 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT TERMS OF REFERENCE PRELIMINARY ISSUE CATEGORIES AND SUBJECTS Issue Category Issue Subject Project Construction Project Operations Project Phases Project Closure Project Post-Closure Mine site operations and facilities Project Details Siting / Location Proponent Project Schedule Regulatory / EA Process Project / EA Management Project Description Project Support Public Participation Aboriginal Consultation Surface Water Quality Surface Water Quantity Water Groundwater Quality Groundwater Quantity Aquatic and Terrestrial Habitat Biology Aquatic and Terrestrial Biota Site Geology Geology Geochemistry Employment Hunting and Fishing Community Infrastructure Traffic and Transportation Socio-Economic Population Demographics Education and Training Human Health and Safety Public Health Traditional Land Use Aboriginal Interests Traditional Knowledge I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Tables\[Tables and 11.3.xlsx]Table 11.1 Print Mar/28/12 13:54: MAR'12 ISSUED WITH REPORT ALR JSP SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D Page 1 of 1

77 TABLE 11.2 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT TERMS OF REFERENCE SUMMARY OF ABORIGINAL ENGAGEMENT MEETINGS Date Communication Summary Participants Webequie First Nation March 29, 2010 Meeting for purposes of providing a copy of the project description. Marten Falls First Nation April 6, 2010 Meeting for purposes of addressing community issues. Marten Falls First Nation April 9, 2010 Meeting for purposes of addressing community issues. Webequie First Nation Print Mar/28/12 13:54:40 August 2 & 3, 2010 September 2, 2010 March 15, 2011 Meeting for the purposes of providing an update to the community capacity skills survey. Meeting to introduce the proposed ATK study and proposed project route corridor. Meeting to provide project information to community members and ATK study information. Webequie First Nation Webequie First Nation Webequie First Nation April 11, 2011 Meeting to provide project information. Eabametoong First Nation April 20, 2011 Meeting to provide a project update, to discuss the proposed business opportunities and to offer a project Open House. Webequie First Nation June 20, 2011 Meeting to discuss the Airstrip and business development. Marten Falls First Nation June 30, 2011 Meeting to discuss project update. Long Lake First Nation #58 September 13, 2011 October 6, 2011 Meeting to discuss corridor to Webequie First Nation junction and the ongoing work at the site. Meeting to discuss the Wilderness North having access to the land adjacent to the airstrip. Webequie First Nation Marten Falls First Nation October 11, 2011 Meeting to discuss business opportunities. Métis Nation of Ontario October 13, 2011 Meeting to discuss road development. Mishkeegogamang First Nation October 14, 2011 Meeting to discuss recent letter from community. Eabametoong First Nation October 20, 2011 Meeting to discuss communities interested in the East- West Corridor. Eabametoong First Nation October 20, 2011 Meeting to discuss the environmental assessment processes. Nimbinik First Nation, Ginoogamang First Nation, Webequie First Nation, Aroland First Nation, Marten Falls First Nation, Long Lake First Nation # 58, Eabametoong First Nation I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Tables\[Tables and 11.3.xlsx]Table MAR'12 ISSUED WITH REPORT ALR JSP SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D Page 1 of 1

78 TABLE 11.3 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT TERMS OF REFERENCE PRELIMINARY SUMMARY OF ISSUES AND CONCERNS Print Mar/28/12 13:54:40 Issue Subject Employment and Training Social Concerns Treaty Rights Information Sharing Facilities, Permitting Traditional Knowledge Studies Environmental Concerns Summary of Discussion Issues raised relating to business opportunities, employment and training opportunities to bring community members into the industry. Discussion about the potential increasing demands on community infrastructure. Concerns about the increased use of illegal substances with more money in the community through employment. Concerns raised about Aboriginal and treaty rights relating to hunting and trapping. Concerns expressed about the lack of information sharing between Noront and the community. Concerns raised about the development and permitting of the airstrip. Discussion of potential pros and cons to development of all-season road. Concerns raised about sharing information with Noront and issues of trust concerning the use of the information. Concerns raised about previous environmental problems in the region being repeated. I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Tables\[Tables and 11.3.xlsx]Table MAR'12 ISSUED WITH REPORT ALR JSP SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D Page 1 of 1

79 TABLE 13.1 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT TERMS OF REFERENCE PRELIMINARY LIST OF PERMITS, LICENCES AND APPROVALS Print Mar/28/12 13:53:01 Permit/Approval Agency Act Regulations Trigger/Activity Provincial Permits Work Permit MNR Public Lands Act O.Reg. 975/90 Work Permits - road or building construction on public lands. O.Reg. 453/96 Work Permit - Construction - for construction of road facility to enable crossing of a water body Any work on water crossings. (culvert installations, construction of a bridge, seasonal ice bridges) Work Permit MNR Public Lands Act O.Reg. 975/90 Work Permits - for road or building construction on Public Land (Crown Land). Any work that involves upgrading of existing roads or building new roads or trails on Crown Land. Timber Cutting Licence MNR Crown Forest Sustainability Act N/A Tree removal on Crown Land Approval MNR Lakes and Rivers Improvement Act N/A Water Retaining Structures Land Use Permit MNR Public Lands Act Work Permit MNR Public Lands Act Public Lands Act O.Reg. 973/90 land use permits O.Reg. 453/96 - Work Permit - Construction - for construction of buildings on public land When land tenure is required to use Crown land for building Construction of buildings on public land (road construction camps) Burning permit MNR Forest Fire Prevention Act O.Reg. 207/96 Outdoor Fires Burning of removed vegetation Aggregate Permit/Licence MNR Ontario Aggregate Resources Act (ARA) O.Reg. 244/97 Removal of aggregate from pit or quarry (road construction) Certificate of approval - Industrial Sewage Works MOE Ontario Water Resources Act O.Reg. 560/94 Effluent Monitoring and Effluent Limits - metal mining sector. O.Reg 561/94 Effluent monitoring and Effluent Limits Industrial minerals Sector Industrial sewage works Certificate of approval MOE Safe Drinking Water Act O. Reg. 169/03 Ontario drinking water quality standards. O.Reg. 170/03 Drinking water systems. Potable water supply Approval MOE Clean Water Act O. Reg. 287/07 Source Protection Plan Certificate of approval - Air and Noise MOE EPA O.Reg. 419/05 Air pollution - Local Air Quality O.Reg Ambient Air Quality Criteria Discharge of an airborne contaminant into the natural environment, including noise (generators and incinerator) Generator Registration Report MOE EPA O.Reg. 347/90 General - Waste management Storage and transportation of hazardous wastes. Certificate of approval MOE EPA N/A Discharge of industrial wastewaters to surface water as a result of industrial process Certificate of approval MOE EPA N/A Construction of a waste disposal site Certificate of approval - Domestic Sewage Works MOE Ontario Water Resources Act O.Reg. 560/94 Effluent Monitoring and Effluent Limits - metal mining sector. O.Reg 561/94 Effluent monitoring and Effluent Limits Industrial minerals Sector Discharge of domestic sewage to surface or ground water Permit to Take Water (>50,000 L) MOE Ontario Water Resources Act O.Reg. 387/04 Water Taking Taking more than 50,000 L per day Building/Land Use Permit Ministry of Transportation Public Transportation and Highway Improvement Act N/A Building near highways Entrance Permit Ministry of Transportation Public Transportation and Highway Improvement Act N/A Requirement for a new or upgraded road entrance onto a provincial highway Page 1 of 2

80 TABLE 13.1 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT TERMS OF REFERENCE PRELIMINARY LIST OF PERMITS, LICENCES AND APPROVALS Print Mar/28/12 13:53:01 Permit/Approval Agency Act Regulations Trigger/Activity Encroachment Permit Ministry of Transportation Public Transportation and Highway Improvement Act N/A Activities within 45 m of the highway may be controlled for safety considerations Verification of Closure Plan Completion MNDMF Mining Act O.Reg 240/00 Mine development and Closure Plan Completion of closure plan Notice of Project Status MNDMF Mining Act O.Reg 240/00 Public Notification Pre-development review process MOL Occupational health and safety Act Occupational Health and Safety O.Reg 854/90 Mines and Mining Plants Requires safety and procedures review of project prior to development Federal Permits Permit NRcan Explosives Act Section 7 N/A Explosives Use Licence for explosives Magazine NRcan Explosives Act Section 7 N/A Fish Habitat Authorization DFO Fisheries Act Fishery (General) Reg (SOR/93-53) Required for constructing or maintaining an explosives magazine Work on water crossings or work near water that is fish habitat. Approval TC Navigable Waters Protection Act Navigable Waters Works Regulations Any Work for crossing a navigable water body that may interfere substantially with navigation. (Muketei Bridge) TC Construction of Airstrip Provincial EA Process Class EA approval Ministry of Transportation Environmental Assessment Act N/A Construction or realignment of a provincial highway Individual EA approval MOE Ontario Environmental Assessment Act O.Reg electricity projects > 5 MW need individual EA process Class EA approval MOE Ontario Environmental Assessment Act O.Reg electricity projects Class EA required if Project connects to the provincial grid (115 kv) Class EA approval MNR Ontario Environmental Assessment Act N/A Disposition of Rights to Crown Resources Federal EA Process Approval CEAA Canadian Environmental Assessment Act N/A Federal involvement in the Project. Federal issued Permits, Licences and Approvals. I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Tables\[Table 13.1.xlsx]Table 13.1 NOTES: 1. MNDMF - ONTARIO MINISTRY OF NORTHERN DEVELOPMENT, MINES AND FORESTRY. 2. MOE - ONTARIO MINISTRY OF THE ENVIRONMENT. 3. MNR - ONTARIO MINISTRY OF NATURAL RESOURCES. 4. MOL- ONTARIO MINISTRY OF LABOUR. 5. DFO - DEPARTMENT OF FISHERIES AND OCEANS. 6. TC - TRANSPORT CANADA. 7. CEAA - CANADIAN ENVIRONMENTAL ASSESSMENT AGENCY. 8. NRCAN - NATURAL RESOURCES CANADA. 9. EPA - ENVIRONMENTAL PROTECTION ACT. 0 27MAR'12 ISSUED WITH REPORT JSP ALR REV DATE DESCRIPTION PREP'D CHK'D APP'D SRA Page 2 of 2

81 TABLE 13.2 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT TERMS OF REFERENCE PRELIMINARY LIST OF POLICIES, GUIDELINES, CRITERIA AND STANDARDS Agency Topic Documentation Determination of Contaminant Limits and Attenuation Zones, Procedure B-7-1 (formerly referenced by 15-08), Ontario Ministry of the Environment Print Mar/28/12 13:53:40 Surface Water Water Management Policies, Guidelines, Provincial Water Quality Objectives of the Ministry of Environment and Energy, July 1994 (reprinted February 1999) MOE 1993 Guidelines for the Protection and Management of Aquatic Sediment Quality in Ontario Incorporation of the Reasonable Use Concept into MOEE Groundwater Management Activities, Guideline B-7 (formerly 15-08), Ontario Water Resources Act, April 1994 Groundwater Technical Guidance Document For Hydrogeological Studies In Support of Category 3 Applications for Permit to Take Water, Ministry of the Environment, Operations Division, April 2008 Ontario Drinking Water Quality Standards, Ontario Regulation 169/03, Safe Drinking Water Act, 2002 Technical Support Document for Ontario Drinking Water Standards, Objectives and Guidelines, June 2003 (revised June 2006), Ontario Ministry of the Environment Waste Management Landfill Standards: A Guideline on the Regulatory and Approval Requirements for New and Expanding Landfilling Sites, Ontario Regulation 232/98, Environmental Protection Act, May 1998 (revised June 2010) MOE Noise Limits: shall comply with the MOE noise limits in: - Publication NPC-205, Sound Level Limits for Stationary Sources in Class 1 & 2 Areas (Urban), October, 1995 as amended; or - Publication NPC-232, Sound Level Limits for Stationary Sources in Class 3 Areas (Rural), October, 1995 as amended; as applicable Noise Screening: shall be prepared in accordance with: - General noise screening process for S.9 Applications - Primary noise screening process for S.9 Applications Supplement to application for approval: - Secondary noise screening process for S.9 applications Atmospheric and Noise Noise Reports: shall be prepared in accordance with: - Publication NPC-233, "Information to be Submitted for Approval of Stationary Sources of Sound", October, 1995 as amended - Guide for the Preparation of an Abbreviated Acoustic Assessment Report (A AAR) - Supporting Information for the Preparation of an Acoustic Assessment Report Vibration Limits: shall comply with the MOE vibration limits in: - draft technical publication Impulse Vibration in Residential Buildings, November 1983, supplementing the Model Municipal Noise Control By-Law, Final Report, August Publication NPC-119, Blasting, Model Municipal Noise Control By-Law, Final Report, August 1978 Vibration Reports: shall be prepared in accordance with: - Publication NPC-233, "Information to be Submitted for Approval of Stationary Sources of Sound", October, 1995 as amended - Supporting Information for the Preparation of a Vibration Assessment Report I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Tables\[Table Guidelines, Policies and Standards.xlsx]Table MAR'12 ISSUED WITH REPORT JSP ALR SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D Page 1 of 1

82 I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Figures\[Figure 4.1 AND 41.2.xlsx.xls]FIGURE 4.1 Print 27/03/ :36 AM NOTES: 1. SOURCE: MINISTRY OF THE ENVIRONMENT. NORONT RESOURCES LTD. EAGLE'S NEST PROJECT PROVINCIAL INDIVIDUAL EA PROCESS 0 27MAR'12 ISSUED WITH REPORT JSP ALR SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D P/A NO. NB /1 FIGURE 4.1 REF. NO. 7 REV 0

83 I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Figures\[Figure 4.1 AND 41.2.xlsx.xls]FIGURE 4.2 Print 27/03/ :36 AM NOTES: 1. SOURCE: CANADIAN ENVIRONMENTAL ASSESSMENT AGENCY. NORONT RESOURCES LTD. EAGLE'S NEST PROJECT CEA AGENCY COMPREHENSIVE STUDY PROCESS 0 27MAR'12 ISSUED WITH REPORT JSP ALR SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D P/A NO. NB /1 FIGURE 4.2 REF. NO. 7 REV 0

84 I:\1\02\00390\01\A\Report\Report 7 - Provincial ToR\Figures\[Figure 4.3.xls.xls]FIG 4.3 Print 27/03/ :37 AM NORONT RESOURCES LTD. EAGLE`S NEST PROJECT COORDINATED EA PROCESS 0 27MAR'12 ISSUED WITH REPORT JSP ALR SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D P/A NO. NB /1 FIGURE 4.3 REF. NO. 7 REV 0

85 150,000 > ò" N 300,000 Kasabonika 450, , , ,000 1,050,000 MANITOBA #* EAGLE'S NEST MINE SITE QUEBEC Kingfisher Lake ONTARIO Wunnumin Lake Webequie Attawapiskat 5,850,000 Nibinamik #* EAGLE'S NEST MINE SITE Neskantaga Kashechewan Fort Albany LEGEND: #* EAGLE'S NEST MINE SITE COMMUNITY/SERVICE CENTRE 5,700,000 Pickle Lake Fort Hope / Eabametoong Marten Falls / Ogoki Post Moosonee ROAD RAILWAY WATER PARK Mishkeegogamang FIRST NATIONS RESERVE ONTARIO Sioux Lookout Savant Lake Nakina 5,550,000 Longlac Geraldton Hearst Kapuskasing Smooth Rock Falls Cochrane NOTES: 1. BASE MAP: HER MAJESTY THE QUEEN IN RIGHTS OF CANADA DEPARTMENT OF NATURAL RESOURCES (2009.) ALL RIGHTS RESERVED. 2. CO-ORDINATE GRID IS IN METRES. DATUM: NAD83 PROJECTION: UTM ZONE 16 5,400,000 White River Timmins 3. ROUTE OPTIONS BASED ON INFORMATION PROVIDED BY SNC (MARCH 24, 2011). SAVED: I:\1\02\00390\01\A\GIS\Figs\B149_r0.mxd; Mar 27, :28 AM; amoore 5,250, MAR'12 ISSUED WITH REPORT Thunder Bay ALR ASM ALR SRA REV DATE DESCRIPTION DESIGNED DRAWN CHK'D APP'D Wawa Elk Lake km SCALE NORONT RESOURCES LTD. EAGLE'S NEST PROJECT PROJECT LOCATION MAP P/A NO. REF NO. NB /1 7 FIGURE 5.1 REV 0

86 , , , ,500 > ò" N ,847, AIRSTRIP PROPOSED ACCESS CORRIDOR PROPOSED WINTER ROAD, SLURRY PIPELINE AND TRANSMISSION LINE !( ,845, MUKETEI RIVER !( PROPOSED PERMANENT CAMPSITE/OFFICES PROPOSED WATER MANAGEMENT SETTLING POND!(!( 170!(!(!(!(!(!( 177.5![ ESKER CAMP PROPOSED STOCKPILE (AGGREGATES) ,842, m!( PROPOSED PORTAL LOCATION ( N, E) WASTE MANAGEMENT FACILITY INCINERATOR EXPLOSIVES FACTORY PROPOSED MINE WASTE ROCK PAD KOPER LAKE WATER LANDING AND DOCK KOPER LAKE ,840,000 SAVED: I:\1\02\00390\01\A\GIS\Figs\A43_r0.mxd; Mar 27, :21 AM; amoore LEGEND:!( GROUNDWATER MONITORING WELL LOCATION MINOR CONTOUR MAJOR CONTOUR SITE ROAD STREAM PROPOSED WINTER ROAD CORRIDOR 0 27MAR'12 ISSUED WITH REPORT REV DATE DESCRIPTION 170 PROPOSED LANDFILL SWAMP WATER LOCAL STUDY AREA 170 NOTES: 1. BASE MAP PROVIDED BY SNC LAVALIN INC., CO-ORDINATE GRID IS IN METRES. DATUM: NAD83 PROJECTION: UTM ZONE CONTOUR INTERVAL IS 1.5 METRES. 4. INFRASTRUCTURE IS BASED ON INFORMATION PROVIDED BY NORONT RESOURCE LTD., 2010 AND IS PROPOSED ONLY. 170 ALR ASM ALR SRA DESIGNED DRAWN CHK'D APP'D ,000 1,500 2,000 2,500 m SCALE NORONT RESOURCES LTD. EAGLE'S NEST PROJECT LOCAL STUDY AREA EAGLE'S NEST MINE SITE P/A NO. REF NO. NB /1 7 FIGURE REV 0

87 467, , ò" > ,000 m NORONT RESOURCES LTD. EAGLE'S NEST PROJECT LOCAL STUDY AREA WEBEQUIE JUNCTION P/A NO. REF NO. NB /1 7 REV 0 FIGURE SCALE , NOTES: 1. BASE MAP: HER MAJESTY THE QUEEN IN RIGHTS OF CANADA DEPARTMENT OF NATURAL RESOURCES (2009). ALL RIGHTS RESERVED. 2. COORDINATE GRID IS IN METRES. COORDINATE SYSTEM: NAD 1983 UTM ZONE 16N. 3. CONTOUR INTERVAL IS 1 METRE. 4. INFRASTRUCTURE SHOWN FROM PROJECT DESCRIPTION. INFRASTRUCTURE IS PROPOSED ONLY AND MAY BE SUBJECT TO CHANGE. 5. ROUTE OPTIONS BASED ON INFORMATION PROVIDED BY SNC (MARCH 24, 2011). 464, , WATER WETLAND PROPOSED INFRASTRUCTURE WEBEQUIE JUNCTION CLAIMS WEBEQUIE JUNCTION LOCAL STUDY AREA ALR ASM ALR SRA DESIGNED DRAWN CHK'D APP'D , , N ,845, ,844, ,843,000 LEGEND: PROPOSED ACCESS CORRIDOR CONTOUR (MINOR) CONTOUR (MAJOR) RIVER/STREAM/DRAINAGE PROPOSED INFRASTRUCTURE ISSUED WITH REPORT 27MAR'12 0 DESCRIPTION DATE REV SAVED: I:\1\02\00390\01\A\GIS\Figs\A44_r0.mxd; Mar 27, :23 AM; amoore

88 , , , , ,600 > ò" N 5,572,500 SAVANT LAKE![ SAVANT LAKE CONCENTRATE TRANSFER FACILITY 5,570, PROPOSED ACCESS ROUTE m BUFFER 440 5,567, SAVED: I:\1\02\00390\01\A\GIS\Figs\A45_r0.mxd; Mar 27, :24 AM; amoore LEGEND: ROAD WINTER/SERVICE/RESOURCE/RECREATION ROAD RAILWAY CONTOUR RIVER/STREAM/DRAINAGE PROPOSED ACCESS ROAD 0 27MAR'12 ISSUED WITH REPORT REV DATE DESCRIPTION SAVANT LAKE LOCAL STUDY AREA WATER WETLAND 120 m BUFFER ALR ASM ALR SRA DESIGNED DRAWN CHK'D APP'D NOTES: 1. BASE MAP: HER MAJESTY THE QUEEN IN RIGHTS OF CANADA DEPARTMENT OF NATURAL RESOURCES (2009). ALL RIGHTS RESERVED. 2. COORDINATE GRID IS IN METRES. COORDINATE SYSTEM: NAD 1983 UTM ZONE 16N. 3. CONTOUR INTERVAL IS 20 METRES ,000 1,500 2,000 2,500 m SCALE 460 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT LOCAL STUDY AREA SAVANT LAKE P/A NO. REF NO. NB /1 7 FIGURE 7.3 REV 0

89 320,000 > ò" N 5,880,000 KINGFISHER LAKE 360, , , ,000 WINISK RIVER PROVINCIAL PARK 520, ,000 LEGEND:![ EAGLE'S NEST MINE SITE AND WEBEQUIE JUNCTION COMMUNITY/SERVICE CENTRE ROAD ALL-SEASON WINTER/SERVICE/RESOURCE/RECREATION ROAD PROPOSED ALL-SEASON ROAD PROPOSED WINTER ROAD CORRIDOR ACCESS CORRIDOR LOCAL STUDY AREA FIRST NATIONS RESERVE WEBEQUIE WATER PIPESTONE RIVER PROVINCIAL PARK WUNNUMIN LAKE PROVINCIAL PARK 5,840,000 NIBINAMIK WEBEQUIE JUNCTION EAGLE'S NEST![![ MINE SITE 5,800,000 OTOSKWIN-ATTAWAPISKAT RIVER PROVINCIAL PARK NESKANTAGA 5,760,000 NOTES: 1. BASE MAP: HER MAJESTY THE QUEEN IN RIGHTS OF CANADA DEPARTMENT OF NATURAL RESOURCES (2009). ALL RIGHTS RESERVED. 2. CO-ORDINATE GRID IS IN METRES. DATUM: NAD83 PROJECTION: UTM ZONE 16 N 3. ROUTE OPTIONS BASED ON INFORMATION PROVIDED BY SNC (MARCH 24, 2011). SAVED: I:\1\02\00390\01\A\GIS\Figs\B77_r0.mxd; Mar 27, :44 PM; amoore 5,720,000 WABAKIMI PROVINCIAL PARK 0 27MAR'12 ISSUED WITH REPORT ALR ASM ALR SRA REV DATE DESCRIPTION DESIGNED DRAWN CHK'D APP'D ALBANY RIVER PROVINCIAL PARK FORT HOPE / EABAMETOONG SCALE km NORONT RESOURCES LTD. EAGLE'S NEST PROJECT LOCAL STUDY AREA ACCESS CORRIDOR & PIPELINE P/A NO. REF NO. NB /1 7 FIGURE 7.4 REV 0

90 6,000,000 OPASQUIA PROVINCIAL PARK > ò" N 200,000 BEARSKIN LAKE 300,000 WAWAKAPEWIN 400,000 KASABONIKA 500, , ,000 POLAR BEAR PROVINCIAL PARK LEGEND:![ EAGLE'S NEST MINE SITE, WEBEQUIE JUNCTION AND SAVANT LAKE CONCENTRATE TRANSFER FACILITY COMMUNITY/SERVICE CENTRE ROAD ALL-SEASON WINTER/SERVICE/RESOURCE/RECREATION ROAD RAILWAY PROPOSED ALL-SEASON ROAD PROPOSED WINTER ROAD CORRIDOR PROJECT REGIONAL STUDY AREA FIRST NATIONS RESERVE WATER PROVINCIAL PARK 5,900,000 WEAGAMOW LAKE KINGFISHER LAKE WUNNUMIN LAKE WEBEQUIE NIBINAMIK![ WEBEQUIE JUNCTION![ EAGLE'S NEST MINE SITE 5,800,000 NESKANTAGA CAT LAKE MARTEN FALLS / OGOKI POST 5,700,000 PICKLE LAKE FORT HOPE / EABAMETOONG SLATE FALLS MISHKEEGOGAMANG NOTES: 1. BASE MAP: HER MAJESTY THE QUEEN IN RIGHTS OF CANADA DEPARTMENT OF NATURAL RESOURCES (2009). ALL RIGHTS RESERVED. SAVED: I:\1\02\00390\01\A\GIS\Figs\B78_r0.mxd; Mar 27, :30 AM; amoore 5,600,000 SIOUX LOOKOUT SAVANT LAKE OJIBWAY NATION OF SAUGEEN SAVANT LAKE![ SAVANT LAKE CONCENTRATE TRANSFER FACILITY A 27MAR'12 ISSUED WITH REPORT ALR ASM ALR SRA REV DATE DESCRIPTION DESIGNED DRAWN CHK'D APP'D WABAKIMI PROVINCIAL PARK ARMSTRONG NAKINA 2. CO-ORDINATE GRID IS IN METRES. DATUM: NAD83 PROJECTION: UTM ZONE 16 N SCALE km NORONT RESOURCES LTD. EAGLE'S NEST PROJECT REGIONAL STUDY AREA P/A NO. REF NO. NB /1 7 FIGURE 7.5 REV 0

91 APPENDIX A CONSULTATION PLAN (Pages A-1 to A-35)

92 NORONT RESOURCES LTD. EAGLE S NEST PROJECT CONSULTATION PLAN NB /1-9 March 26, 2012 A-1 of 35

93 A-2 of 35

94 NORONT RESOURCES LTD. EAGLE S NEST PROJECT CONSULTATION PLAN (REF. NO. NB /1-9) TABLE OF CONTENTS PAGE SECTION INTRODUCTION INTRODUCTION... 1 SECTION BACKGROUND... 2 SECTION OBJECTIVES... 4 SECTION STAKEHOLDER AND ABORIGINAL COMMUNITY IDENTIFICATION INTRODUCTION ABORIGINAL COMMUNITIES Initial Identification by Noront Preliminary Screening by Noront Summary of Screening Provision of a List by Government Agencies Aboriginal Groups Identified PROVINCIAL AND FEDERAL GOVERNMENT MUNICIPAL GOVERNMENT GENERAL PUBLIC INCLUDING COMMERCIAL/INDUSTRIAL INTEREST NON-GOVERNMENTAL ORGANIZATIONS... 9 SECTION CONSULTATION AND ENGAGEMENT METHODS INTRODUCTION CONSULTATION STRATEGY Phase 1: Pre-Consultation Phase 2: Consultation on and during the preparation of the Terms of Reference Phase 3: Consultation during preparation of the EA Phase 4: Post EA/ongoing engagement ABORIGINAL ENGAGEMENT Information Sessions First Nations Field Guides Community Engagement Community Meetings PUBLIC ENGAGEMENT GOVERNMENT REVIEW SECTION KEY MILESTONES FOR CONSULTATION i of ii NB /1-9 March 26, 2012 A-3 of 35

95 6.1 INTRODUCTION NOTICES REPORT PUBLICATION COMMUNITY OPEN HOUSE EVENTS WEB PORTAL ADDITIONAL COMMUNICATION TOOLS SECTION TRADITIONAL KNOWLEDGE PLAN INTRODUCTION INFORMATION REQUIRED METHODS OF DATA COLLECTION INCORPORATION OF ATK SECTION ISSUE IDENTIFICATION AND TRACKING SECTION CONSIDERATION OF COMMENTS INTRODUCTION ISSUE RESOLUTION SECTION ONGOING CONSULTATION PLANNING SECTION CERTIFICATION TABLES Table 4.1 Table 5.1 Stakeholder Engagement List - Stakeholders, Aboriginal Groups and Government Review Team Consultation Phases, Activities and Materials FIGURES Figure 4.1 Figure 4.2 Figure 4.3 Aboriginal Regional Study Area Aboriginal Local Study Area Historical Settlements and Archeological Complexes NB /1-9 March 26, 2012 ii of ii A-4 of 35

96 NORONT RESOURCES LTD. EAGLE S NEST PROJECT CONSULTATION PLAN (REF. NO. NB /1-9) SECTION INTRODUCTION 1.1 INTRODUCTION Noront Resources Ltd. (Noront) is proposing to develop the Eagle s Nest Project (Project), a multi-metal underground mine to produce and supply nickel, copper, platinum and palladium. The Project mine site is located approximately 300 km north of Nakina and 530 km northeast of Thunder Bay. Access to the mine site is proposed to consist of an all-season segment and a winter road segment. The proposed all-season road would run from Highway 808, roughly 60 km north by northeast of Pickle Lake, to Webequie Junction. This section would require the realignment and upgrading of the existing winter road into an all-season road. The second section would consist of the construction of a winter road between a transfer facility at Webequie Junction and the proposed mine site. Exploration and preliminary activities have been underway for several years and the Project is now moving to the Environmental Assessment stage. Consultation with stakeholders and Aboriginal communities has been integral to the Project since before the EA process began. Noront s approach to consultation to meet the needs of the Ontario Environmental Assessment Act will follow the guidelines outlined in the Ministry of Environment s Code of Practice for Consultation in Ontario s Environmental Assessment Process (2007). Where possible, consultation on the federal Canadian Environmental Agency (CEA Agency) process and the provincial Environmental Approvals Branch (EAB) process will be linked and coordinated. Noront will attempt to meet the requirements of both agencies by combining consultation events so as to maximize stakeholder interaction and feedback. The Consultation Plan outlined in this report shows how Noront will consult and engage with stakeholders and Aboriginal communities. Moreover, the plan is structured to meet the following Ministry of the Environment (MOE) requirements: Proposed consultation methods (Section 5) How input will be obtained (Section 5 and 8) Key decision-making milestones (Section 6 ) Issues resolution strategy (Section 9) This Consultation Plan outlines the minimum requirements for the activities that Noront will undertake as part of the EA process. The specific details are flexible and can be finalized based on ongoing feedback from Aboriginal communities, the public and government reviewers. In particular, Aboriginal communities will be engaged in a discussion regarding how they wish to be consulted, before any plans are finalized. Communities will have an opportunity to provide input on potential consultation plans before they are carried out. NB /1-9 March 26, of 26 A-5 of 35

97 SECTION BACKGROUND Engagement with Aboriginal communities by Noront began shortly after the discovery of the Eagle's Nest deposit in It has continues as Noront has moved into project planning and development. Early engagement activities commenced in March 2010 and consisted of information sharing, early identification and scoping of community interests and concerns, completing an Aboriginal skills survey with the Marten Falls and Webequie First Nations, and providing updates as to preparations for requisite and applicable environmental assessment review processes. Since March 2010, much of the engagement and early consultation initiatives and efforts have been guided by the interest and priorities expressed by Aboriginal communities. The consultation program and engagement activities have been and will continue to be guided by Noront's Aboriginal Policy. Aboriginal communities have each expressed differing views, interests and concerns in relation to the Project. Concerns have been expressed about the technical aspects of the Project design, the impact mitigation and effects monitoring, and how a First Nation could work with Noront to address socio-economic and socio-cultural priorities. Most Aboriginal communities within close proximity to the Project have expressed an interest in working with Noront and government agencies to develop an informed view of the Project. Communities are generally receptive and have requested additional information to better understand the Project plans. Open houses have now been held in most of the communities likely to be impacted by the Project, and input from these has been incorporated into the draft Terms of Reference (ToR). Four communities (Webequie, Nibinamik, Eabametoong and Neskataga) have signed an agreement to work together to plan, construct and maintain the proposed all-season road corridor should it be approved. Marten Falls First Nation is working with Noront to own and manage the Esker camp. They are also interested in owning, constructing and managing the proposed all-season airstrip. Discussions are ongoing for other business opportunities related to Project development. Noront has made considerable efforts to include and utilize businesses and organizations in local communities. Furthermore, there has been discussion on how to include communities in the future. Noront has been employing Cyr Drilling which is owned in part by Webequie First Nation. There has been discussion with Webequie on the use of local businesses, motel accommodations, rental of office space in the community and the use of the community employment office for short term workers. Noront has hired a local Community Liaison officer. In Marten Falls, Noront has had discussions focused on developing opportunities to supply food to the camp. There have also been discussions on the ownership of exploration facilities and how to transition ownership of the seasonal ice airstrip. In 2009, the number of First Nation employees involved in the Project, both direct and indirect, was less than 10% of the total workforce. Presently, two First Nation individuals are in middle and senior management positions and First Nation workers account for over one third of the total workforce at the exploration camp. Noront encourages the hiring of local workers for all Project activities. Direct employment opportunities are offered to the local communities whenever Project work becomes available. Moreover, Noront encourages contractors to hire local workers from potentially affected communities. As a result, First Nation employment numbers continue to increase. NB /1-9 March 26, of 26 A-6 of 35

98 Aboriginal communities have expressed a range of interests, issues, concerns and values that they wish to have addressed during the environmental assessment process. In general, communities want to have a considerable stake in the Project. In addition to the engagement with Aboriginal communities, Noront has carried out extensive discussions with government agencies and ministries during the preparation of the ToR and the EIS Guidelines. Specifically, meetings and discussions have been held with the provincial MOE, MNR, MNDM and Ring of Fire Secretariat, and with the federal CEA Agency and with MPMO. These discussions will continue throughout the EA process and beyond, to ensure that the requirements of the various ministries and agencies are properly met. Noront has benefited greatly from the meetings and discussions held to date, as these have helped to focus the Company s efforts on the critical issues that it will face as it moves the Eagle s Nest Project though the EA process. The draft ToR, the EIS Guidelines and the Project Description have all been made available for public comment through the Noront and Eagle s Nest websites. Noront attended an information meeting in the community of Greenstone in 2011, and held an open house in Thunder Bay in January, Comments from both these meetings have been incorporated into the ToR. NB /1-9 March 26, of 26 A-7 of 35

99 SECTION OBJECTIVES Consultation is a central objective of the provincial EA process. Noront has reviewed the MOE Code of Practice on Preparing and Reviewing the Terms of Reference for Environmental Assessments in Ontario (2009) and Consultation in Ontario s Environmental Assessment Process (2007) while developing the following Draft Consultation Plan. The following are elements of a successful Consultation Plan, as suggested by MOE, and have been included in this Draft Eagle s Nest Consultation Plan: Clear Objectives Stakeholder identification Consultation Methods Issue Identification Integration of Input Proponent Evaluation of Consultation Meaningful consultation requires that Noront address concerns of all identified stakeholders regarding the anticipated or potential environmental effects of the Project. In carrying out the EA, Noront will consult residents and organizations in affected communities, other interested organizations, and relevant government agencies. Noront will provide in the EA report a detailed record of this consultation, including the methods used, the results, and the ways in which the proponent intends to address the concerns identified, including a summary of issues raised by stakeholders. As outlined in The Code of Practice: Consultation in Ontario s Environmental Process (2007), a consultation plan must: Indicate how potentially interested and affected persons, including Aboriginal peoples, will be identified, notified and consulted Indicate how government agencies will be identified, notified and consulted Identify the points in the environmental assessment process when interested persons will be consulted Identify the decisions that interested persons can provide input and what role they can play when the proponent makes choices Acknowledge and attempt to address concerns raised during the environmental assessment process In addition, as stated in The Code of Practice: Preparing and Reviewing Terms of Reference for Environmental Assessments in Ontario (2009), the consultation plan should outline: The general consultation methods proposed How input from interested persons will be obtained A description of key decision-making milestones during the preparation of the environmental assessment when consultation will occur Issue resolution strategy NB /1-9 March 26, of 26 A-8 of 35

100 Based on the above requirements, the objectives of Noront s Eagle s Nest Consultation Plan are to: Implement consultation with Aboriginal communities and the public early in the process and continue consultation through the regulatory process, as well as through the construction and operations phases should the Project receive approval Provide Aboriginal communities and organizations and the public with Project information in a timely, ongoing and sensitive manner so they can consider such information in determining their interests, if any, in the Project Improve community and stakeholder understanding of technical issues and reports Increase knowledge of the potential environmental effects of the Project by Aboriginal communities and the public Provide opportunities for Aboriginal communities and organizations and the public to identify issues, interests and potential Project impacts Facilitate dialogue between Noront and communities/stakeholders Respond to all issues and concerns raised by Aboriginal communities and the public Provide a range of opportunities for comments and concerns to be heard Gather ongoing feedback from Aboriginal communities, the public and government reviewers regarding the proposed approach to consultation, and adjust the consultation plan to meet their needs Indicate how information and concerns of Aboriginal communities and the public have been considered and taken into account in the design and planning of the Project Avoid, reduce or mitigate, as appropriate, potential effects of the Project on Aboriginal interests and support Crown efforts and plans to accommodate Aboriginal interests when required Disseminate the results of the environmental assessment process Provide opportunities for discussion and seek joint issue resolution, where reasonably possible Engage relevant government agencies to review the Consultation Plan and ensure that it satisfies their consultation requirements Engage relevant government agencies in the consultation process and provide information related to Noront consultation activities and any specific interests and concerns brought forth by Aboriginal communities. Assess the capacity of each First Nation and Métis group to participate meaningfully in the consultation process, including the need for financial aid, training and professional support. Identify and explore means for offsetting potential adverse socio-economic effects with opportunities for participation by Aboriginal people in the Project by way of education, employment and business opportunities NB /1-9 March 26, of 26 A-9 of 35

101 SECTION STAKEHOLDER AND ABORIGINAL COMMUNITY IDENTIFICATION 4.1 INTRODUCTION Stakeholders in the Project include those that have a direct interest in the Project or have the potential to be affected by the Project. Stakeholders have been grouped into the following categories: Government (Municipal, provincial, federal), Aboriginal communities, non-governmental organizations, and the general public. Table 4.1 provides an overview of the interested peoples engaged to date. Initial stakeholder identification was based on experience, background research, advice from regulators and local knowledge. It is anticipated that the stakeholder table will be refined and expanded as consultation on the Project moves forward. Stakeholders have been identified and will be identified using the following criteria: Have the potential to be affected by the potential environmental effects of the Project Possess an interest in the Project Live in proximity to the Project; resident in or have jurisdiction over the proposed development area 4.2 ABORIGINAL COMMUNITIES Identification of Aboriginal communities was completed in consultation with government agencies and through a desktop screening exercise Initial Identification by Noront Preliminary contact was undertaken by Noront with communities after the discovery of the high grade nickel/copper massive sulphide deposit in A formal engagement process was undertaken with Webequie and Marten Falls First Nations in Noront has also held discussions with additional communities identified as having potential impacts related from the planned development at Eagle s Nest Preliminary Screening by Noront A desktop review of publicly available information concerning Aboriginal interests was conducted by Noront as a due diligence exercise. This information was largely found on Canadian and Aboriginal government websites and verified by local sources. A series of seven questions were developed as a transparent and repeatable method for preliminary determination of which Aboriginal communities may have an interest in the Project. A Regional Study Area (RSA) and Local Study Area (LSA) were preliminarily defined for the purposes of the screening. The RSA is defined as the Treaty 9 area, and the LSA is defined by the communities closest to the Project facilities (Figures 4.1 and 4.2). NB /1-9 March 26, of 26 A-10 of 35

102 The following seven questions were asked to complete the screening: Is an Indian Reserve or First Nation identified in the RSA by Aboriginal Affairs and Northern Development Canada? Are there licensed traplines identified in the RSA? Is a current settlement or community identified in the RSA by the Métis Nation of Ontario? Is a traditional harvesting area identified in the RSA by the Métis Nation of Ontario? Is a historic community or archaeological complex identified in the RSA by Natural Resources Canada (Figure 4.3)? Is a treaty area identified in the RSA and are there any applicable treaty rights? Are active land claims in the RSA identified by AANDC? Summary of Screening The follow points summarize the results of the screening: The RSA is home to 36 First Nation Communities The closest First Nation community to the proposed project is Webequie First Nation There are three communities that claim direct impact to project site in an overlapping claim territory (Webequie, Marten Falls and Neskantaga First Nations) The closest identified Métis group is more than 300 kms to the south west The RSA covers parts of two treaty areas, Treaty #3 and Treaty #9 The Reserves in the RSA and LSA have their origins in a pre-contact existence (historical settlements) where the Ojibway, Oji-Cree and Cree practised traditional activities After contact with Europeans, Treaty 9 and the Adhesion to Treaty 9 were signed guaranteeing the Ojibway, Oji-Cree and Cree Tribes the right to hunt and fish The RSA includes one possible Métis Harvesting Areas where Métis rights are exercised and managed through local Métis Councils and Captains of the Hunt Lands within the RSA are the subject of ongoing legal actions with the Crown, mostly the result of breach of treaty obligations under Treaty #9 and #3 between the governments of Canada and Ontario Provision of a List by Government Agencies Noront formally requested from CEA Agency a list of Aboriginal communities who should be consulted as part of the Project. CEA Agency has provided a list which included the First Nations listed below and the following additional organizations and communities: Métis Nation of Ontario - Geraldton Discussions with the provincial government ensured that all potentially affected communities were identified. Noront has contacted all of the above listed organizations and communities and will continue to engage with them throughout the EA process. NB /1-9 March 26, of 26 A-11 of 35

103 4.2.5 Aboriginal Groups Identified The communities most likely to be affected by any aspect of the Project include: Webequie First Nation Marten Falls First Nation Nibinamik First Nation Eabametoong First Nation Neskantaga First Nation Aroland First Nation Constance Lake First Nation Long Lake #58 First Nation Ginoogaming First Nation Constance Lake First Nation Attawapiskat First Nation Weenusk (Peawunuk) First Nation Ojibway Nation of Saugeen Mishkeegogamang First Nation Kasabonika Lake First Nation Métis Nation of Ontario The First Nations discussed above are aligned with Nishnawbe Aski Nation (NAN), formerly known as the Grand Council Treaty No. 9. The NAN is a political territorial organization representing 49 First Nation communities within northern Ontario. The Treaty No. 9 area and adjacent Treaty areas are shown in Figure 4.1. Further detailed information and updated community profiles will be developed through on-going engagement and consultation with Aboriginal communities. Noront places a high priority on communities providing and verifying their own community information for inclusion into the environmental assessment and supporting documents. 4.3 PROVINCIAL AND FEDERAL GOVERNMENT To date, provincial and federal government agencies have been working together to provide a coordinated consultation process. Key contacts for the environmental assessment from provincial and federal governments have been identified as: Ministry of Northern Development and Mines (including Ring of Fire Secretariat) Ministry of Environment Environmental Approvals Branch Canadian Environmental Assessment Agency NB /1-9 March 26, of 26 A-12 of 35

104 Other ministries and government offices that have been involved in consultation, including review of preliminary baseline studies and Noront s environmental assessment, include: Provincial Government Ministry of Labour Ministry of Natural Resources Ministry of Transportation Federal Government Major Projects Management Office (NRCan) Department of Fisheries and Oceans Environment Canada Transport Canada Natural Resources Canada Health Canada Industry Canada 4.4 MUNICIPAL GOVERNMENT The role of Municipal governments in the Eagle s Nest Project is indirect due to the remote location of the specific site and to the considerable distances from the site to any municipal location. The Mayor and Council of the Town of Pickle Lake have been identified as a municipal contact based on the town being located along the proposed transportation corridor. The municipality of Greenstone, Unorganized Municiplailty of Savant Lake, Township of Ignace, and the City of Thunder Bay are also included on the municipal stakeholder list. 4.5 GENERAL PUBLIC INCLUDING COMMERCIAL/INDUSTRIAL INTEREST DeBeers Canada (Victor Mine) Goldcorp (Musselwhite Mine) Cliffs Natural Resources Inc. KWG Resources 4.6 NON-GOVERNMENTAL ORGANIZATIONS To date, meetings have been held with Wildlands League, a chapter of CPAWS, to explain the Project and discuss potential impacts. Additional NGO`s involved in the Project include Mining Watch, Ecojustice, Environment North and the Wildlife Conservation Society. NB /1-9 March 26, of 26 A-13 of 35

105 SECTION CONSULTATION AND ENGAGEMENT METHODS 5.1 INTRODUCTION A variety of methods will be employed to gather information from stakeholders and disseminate information about the Project. Consultation, participation and negotiation techniques will also be part of consultation activities as the planning process progresses, since consultation must meet the needs of Aboriginal communities. Plain language information sharing is the top priority in all communications with the public and Aboriginal communities. Technical terms will be avoided wherever possible and a glossary of terms will be developed for circulation at community events. Noront recognizes that support may need to be provided to interested stakeholders to participate in the consultation process. Noront will provide funding as necessary to ensure that stakeholders are able to participate and provide meaningful input into the EA process. 5.2 CONSULTATION STRATEGY A multiple phase consultation strategy is being implemented to ensure that the various consultation needs and regulatory requirements are met. There are four phases to the consultation strategy: Phase 1: Pre-Consultation which involves public announcement of the Project and stakeholder relationship building. Phase 2: Consultation on and during the preparation of the TOR. Phase 3: Consultation during preparation of the EA. Phase 4: Post EA/ongoing engagement. Within each phase there are consultation requirements that must take place. A list of mandatory notices that will be required during each phase of the EA and the preparation of the TOR and EA documents are provided for each phase. The Eagle s Nest Project is also subject to a federal EA process, under CEAA. The requirements listed below for each phase are based on the provincial individual EA requirements but also satisfy the requirements of the Federal EA process Phase 1: Pre-Consultation This phase of consultation was focused on building positive working relationships with the various stakeholders. During this phase, Noront met with various government agencies, community groups, and Aboriginal groups to introduce the Project, discuss the various Project components, and gather feedback from key stakeholders. Noront was also consulting with various stakeholders on the development of the Project Description, a requirement under the federal EA process, and consulted with federal and provincial agencies to investigate the possible EA routes. Input from discussion with local First Nations also informed the development of the Project Description. No mandatory notices are required during this phase of consultation. NB /1-9 March 26, of 26 A-14 of 35

106 5.2.2 Phase 2: Consultation on and during the preparation of the Terms of Reference The purpose of this phase is to gather feedback from stakeholders on the proposed ToR for the coordinated EA. Feedback provided during the preparation of the draft ToR has been used to create the ToR and will guide the development of the EA. This phase is important in determining the key issues and concerns with regards to the proposed Project. Comments that were received during the preparation of the ToR have shaped the Consultation Plan and will be utilised to develop the EA work plan. Mandatory notices required during this of phase include: Notice of Commencement of ToR Notice of Submission of ToR Phase 3: Consultation during preparation of the EA The purpose of this phase is to engage stakeholders in the review of the EA findings as they are being developed. The objectives of this phase are to involve the various stakeholders in a review of the EA document as it is being put together, respond to any issues and concerns, and discuss the findings of the EA. Mandatory notices required during this phase include: Notice of Commencement of EA Notices of Public Open Houses Notice of Submission of EA Phase 4: Post EA/ongoing engagement In order to maintain the relationships developed during the consultation process, and to ensure that stakeholders continue to be a part of the Project, it is recognized that consultations will continue beyond the EA process, if approvals are obtained. The form of consultation and level of consultation will vary depending on the level of Project activity. No mandatory notices are required during this phase of consultation. Table 5.1 illustrates proposed engagement activities and methods during each phase of consultation. 5.3 ABORIGINAL ENGAGEMENT Aboriginal engagement activities will mirror consultation undertaken with public and government stakeholders. Noront understands that Aboriginal people have constitutionally protected rights, a unique understanding of the environment, and a special relationship with the land. The Duty to Consult with Aboriginal people lies with the Crown, and although some procedural aspects can be delegated to project NB /1-9 March 26, of 26 A-15 of 35

107 proponents, Noront understands that consultation and the Crown s fiduciary duty towards Aboriginal people cannot be delegated. Noront will engage with Aboriginal Groups who may be potentially affected by the Project and will actively pursue information about Traditional Land Use and Traditional Ecological Knowledge through the First Nations committees, open houses, the planned Elder s forum, one-on-one interviews, and field trips where the Project schedule allows, and as the willingness of First Nations and Métis community members is determined. Noront recognizes that the Eagle s Nest Project is a significant development in a hitherto remote and undisturbed area. In acknowledgment of these facts, and expressed community and public concern, the Company will also commit to: Maintaining ongoing dialogue with the Aboriginal communities about the proposed consultation approach and any adjustments that could better suit their needs Providing forums for comments to be heard beyond standard open house formats and written comments (such as receiving oral comments through a hearing format) Exploring a broader range of options and committing to pursue alternatives that will best meet the needs of communities and stakeholders around methods for explaining or disseminating technical information and providing opportunities for dialogue and input before decisions are made Aboriginal communities will be included on all information mailings, s and notices, and invited to open house events. Community radio and the Wataway television station will also be used for informing the Aboriginal communities about upcoming engagement and consultation events. A strong foundation has been laid over the past several years which will allow for a relationship to grow built on trust and transparency. Noront established a historic First Nations Advisory Council in October This Council guides the company in establishing exemplary relationships with the local First Nations Communities in the Ring of Fire, where the company s primary assets, including the Eagle s Nest and the Blackbird Deposits, are located Information Sessions Information sessions will be organized as open house events wherever possible. Information sessions will be held in communities or a preferred location identified by the Aboriginal group. Information sessions with Aboriginal communities can present more of a logistical and scheduling challenge than public events. For this reason, it is difficult to determine precise meeting times or topics of discussion. Translators are present at the sessions to translate into Ojibwa and Oji-Cree. It is anticipated that the Aboriginal communities will have some ownership of the engagement and consultation process in that they will set the dates and agendas for these meetings. Noront will work with Aboriginal communities to ensure effective and meaningful engagement takes place, and ensure that comments and input received from the communities are responded to and included in the EA. NB /1-9 March 26, of 26 A-16 of 35

108 5.3.2 First Nations Field Guides During baseline studies, Noront has retained several members of local First Nations to assist with fieldwork activities. The presence of First Nations field guides offers a tangible benefit to the communities through employment and training, and allows Noront the benefit of direct access to their local knowledge so that it can be incorporated in the EA. The field monitors have participated, and will continue to participate, in the following field programs: Aquatic and terrestrial biology Surface and groundwater quality sampling Hydrometric data collection Community Engagement Noront has been working at developing strong relationships with the communities in and around the proposed Project. Noront has visited Marten Falls First Nation and Webequie First Nation on a number of occasions, participated in youth gatherings, supported community initiatives and held Project related meetings. The following is a summary of Noront s community engagement activities and initiatives, most of which will continue throughout the EA process and Project development and operation. The results of these activities will inform the preparation of the EA, and will form part of the socio-economic baseline data. Skills Survey In an effort to understand existing community capacity and to assist communities in the maximization of Project opportunities relating to employment and training, Noront conducted a skills survey initiative with Marten Falls and Webequie First Nations members. Information collected during the skills survey will be used to develop a plan to train those community members who are interested in developing new skills and seeking work in the mining industry. Noront is working on developing a greater awareness of the mining industry in all of the community members. Noront will continue to work collectively with Marten Falls and Webequie First Nations to develop skills training. Mining Matters Noront has worked with the Prospectors and Developers Association of Canada (PDAC) Mining Matters organization to bring a session to Marten Falls and Webequie First Nations. Noront personnel accompanied the Mining Matters staff and assisted in the community sessions. The purpose of the sessions was to increase knowledge about the mining industry for youths in the communities. Over 100 youth from both Marten Falls and Webequie participated in the Mining Matters sessions. NB /1-9 March 26, of 26 A-17 of 35

109 Community Liaison Officers Noront has a Manager of Community Relations. This person is well known to all the communities, has a very important role to play when communicating the plans and the activities of the company with regards to the Project, and throughout the EA process. He is a direct contact for the company to the local communities, being able to address concerns and answer questions directly from community residents. Business Development and Support Working closely with Marten Falls and Webequie, Noront is building business development capacity in the communities. Noront has already contracted local businesses for the delivery of fuel and equipment, the use of a local diamond drill company, and an ice airstrip construction and maintenance partnership during the exploration phase of the Project. Noront has also supported meetings with food wholesale companies and communities with the idea of a partnership to supply food to the exploration camp. Business opportunities for the communities in the construction and operation of the Project and its supporting infrastructure will form part of the potential benefits to the communities that will be outlined in the EA. It is expected that training and support for such opportunities will be provided by Noront throughout the EA, and during the life of the Project if approved Community Meetings Noront has held several meetings to introduce the Project to First Nations and Aboriginal communities and to keep them apprised of Project development. Noront is committed to meeting formats that contribute and encourage a two-way flow of information and issue resolution. These could include, but would not be limited to: Community Meetings and Presentations Community Open Houses Meetings with Chief and Council Meetings with First Nations Staff Meetings with interested constituent groups within communities such as elders, trappers, hunters, youth, men s and women s groups Technical Workshops Participation in Tri - Lateral Meetings with Government or government led meetings Site Visits and Field Assessments These community meetings will continue throughout the preparation of the EA and the life of the Project if approved. Noront has supported, and will continue to support, the coordination and conduct of such meetings and assist in defraying some of the costs associated with such meetings. NB /1-9 March 26, of 26 A-18 of 35

110 5.4 PUBLIC ENGAGEMENT Similar to the Aboriginal Engagement activities listed above, Noront will employ a variety of consultation methods and materials to collect and distribute information from public stakeholders. Planned methods for consultation with the Public include: Open Houses Website Updates Community Events One-on-one meetings Mailings and updates Open Houses Open house events are planned to occur in Pickle Lake, Geraldton, Savant Lake and Thunder Bay. In order to attract a broad audience, advertisements will be placed in local media to inform the public of the open house events. Various materials, such as, display boards, project brochures and draft documents will be utilized during the open houses to present Project information. Stakeholders attending the open house sessions will be encouraged to fill out comment/feedback forms. Website Updates A dedicated website has been established by Noront for the Eagle s Nest Project and can be accessed through Noront s corporate website. The website content will be reviewed and revised regularly to include current Project information. The website content includes; contact details, upcoming consultation events, and reports. Community Events Noront plans on attending community events to display information to public stakeholders. Noront will utilize display boards and project brochures to distribute information about the Project. Feedback forms will be available for ongoing comment collection. One-on-one Meetings One-on-one meetings will be held with key stakeholders to listen, understand, and address concerns and issues. A key objective of these meetings is to ensure that stakeholders are fully informed about the Project and have the opportunity to discuss any concerns with Noront advisors and consultants. Mailings and Updates To ensure that every opportunity is made available to those who might wish to comment on, or seek additional information about, the Project Noront will issue periodic mailings and messaging to stakeholders and communities to advise them of updates concerning the Project. NB /1-9 March 26, of 26 A-19 of 35

111 5.5 GOVERNMENT REVIEW Methods for consultation with government representatives will include ongoing dialogue through s, letters and phone calls. Regular information exchange through draft report publications, meetings and presentations is also planned. Open communication with government agencies and locally elected representatives to ensure a clear understanding of the Project plans, and to receive input throughout the EA process, will be fostered. Provincial, federal and municipal agencies and elected representatives will be included on all information mailings and notices, and invited to open house events. Agency representatives will be consulted on Noront s approach to their respective expertise. For example, consultations are currently underway with the Ontario Ministry of Natural Resources (MNR) and the Ministry of the Environment (MOE), and with the Federal Department of Fisheries and Oceans (DFO), with regards to the baseline studies. NB /1-9 March 26, of 26 A-20 of 35

112 6.1 INTRODUCTION SECTION KEY MILESTONES FOR CONSULTATION The five key consultation milestones in the provincial EA process are: Commencement of the Terms of Reference: A requirement of the provincial EA process is that a ToR is developed with participation from stakeholders, Aboriginal communities and the government. A ToR outlines the framework for a project, provides an overview of baseline conditions, and describes how the EA will be carried out. Submission of the Terms of Reference: Once the ToR has been completed, the document will be submitted to the Ministry of Environment for review. The formal submission of the ToR to the MOE initiates a formal 30 day public review period that is administered by the MOE. Noront will continue consultation during this time to gather community support and ensure stakeholders understand how their comments on the Draft ToR were considered and incorporated into the Final ToR. Commencement of the EA Phase: Official commencement of the EA phase will occur if and when the Minister of the Environment decides that an EA prepared in accordance with the proposed ToR will be consistent with the purpose of the EA Act and the public interest. Preparation of the EA Report: Key EA process steps where consultation is planned will include: Reviewing the results of baseline studies or other investigations Confirming the range of alternatives and evaluation methodology Reviewing the results of the evaluation and the selection of a preferred undertaking Identifying potential impacts and proposed mitigation measures Submission of the EA Report: Once substantial consultation has taken place and scientific studies have been completed, the EA Report will be submitted to the Ministry of Environment for review. After submission, there is a seven (7) week public comment period, following which a ministry review is prepared and published and is followed by a further five (5) week public comment period. Each of these milestones requires formal notification and substantial consultation. In addition to regular on-going consultation activities, Noront plans to have a least one major consultation event (i.e., open house) prior to each milestone. The following sections outline Noront s planned consultation activities with Project stakeholders. 6.2 NOTICES Each of the five key milestones and MNDM requirements will require formal notification. Notices will be developed by Noront, and placed on the Project website and as an advertisement in local newspapers and radio stations including the Thunder Bay Chronicle, the Wawatay News and the Geraldton-Long Lac Times-Star. Where possible, notices will include an invitation to attend a community event where further information can be obtained and comments can be provided to Noront team members in written or oral NB /1-9 March 26, of 26 A-21 of 35

113 form. Open houses will be arranged where possible to offer the opportunity for comment and input to be received directly. Contact information, including a street address, address and toll-free phone number, will be provided to enable stakeholder communication with Noront outside of scheduled events. 6.3 REPORT PUBLICATION Draft and Final Reports will be available online at: and in hard copy at the following locations: Ministry of the Environment Environmental Approvals Branch 2 St. Clair Avenue West, Floor 12 A Toronto, ON M4V 1L / Ministry of the Environment Thunder Bay Regional Office Suite James St. S., 3rd Floor Thunder Bay ON P7E 6S7 Ministry of Northern Development and Mines Suite B James St. S. Thunder Bay, ON P7E 6S Ministry of Northern Development and Mines Ring of Fire Secretariat, Thunder Bay Office 435 James St. S. 3rd Floor Thunder Bay ON P7E 6S7 Noront Resources Ltd. 105 Adelaide Street West, Suite 1100 Toronto, ON M5H 1P Noront Resources Ltd. 886 Alloy Place, Thunder Bay, ON P7B 6E6 NB /1-9 March 26, of 26 A-22 of 35

114 Greenstone Public Library Geraldton Branch 405 Second Street W. P.O. Box 40 Geraldton, ON POT 2H0 Greenstone Public Library - Nakina Branch 216 North Street, P.O. Box 300 Nakina ON P0T 2H0 Pickle Lake Clerk s Office 2 Anne Street, P.O. Box 340 Pickle Lake, ON P0V 3A0 The reports will also be available at the First Nation band offices of potentially affected communities. Communities include: Webequie First Nation Marten Falls First Nation Nibinamik First Nation Neskantaga First Nation Eabametoong First Nation Aroland First Nation Long Lake #58 First Nation Ginoogaming First Nation Constance Lake First Nation Mishkegogamang First Nation Savant Lake First Nation Weenusk First Nation Attawapiskat First Nation Métis Nation of Ontario The notices will indicate that all comments and any questions about the Project should be directed to: consultation@norontresources.com Noront Resources Ltd. 105 Adelaide Street West, Suite 1100 Toronto, Ontario Canada M5H 1P COMMUNITY OPEN HOUSE EVENTS A community open house is planned for each of the key milestones outlined above. Open house events provide community members with a face to face opportunity to comment on draft reports and ask questions of the Project team. Where final reports have been published, the open house will allow NB /1-9 March 26, of 26 A-23 of 35

115 attendees to better understand how their comments were considered and incorporated. Information about the concurrent federal CEAA process, for example the Environmental Impact Study Guidelines, will be included in open house information materials as appropriate to minimize duplicated consultation efforts. Each open house will have information panels with plain language information, fact sheets for attendees to take home and comment forms to collect feedback. As mentioned earlier (Section 5.3) Noront will provide forums for comments to be heard beyond standard open house formats and written comments (such as receiving oral comments through a hearing format). The Company will also explore a broader range of options and commit to pursue alternatives that will best meet the needs of communities and stakeholders around methods for explaining or disseminating technical information and providing opportunities for dialogue and input before decisions are made. 6.5 WEB PORTAL Noront launched the web portal Mikawaa ( in October 2010, an interactive Consultation Portal developed for engagement of First Nation communities. The goal of this portal is to open a respectful, responsible, and knowledgeable dialogue with the communities surrounding the Project. The objective is to understand the communities' concerns, issues, and goals. While learning from the surrounding communities, Noront also wants to share information on our activities and plans. Noront believes that through open dialogue, effective communication and mutual understanding, we will take the first steps to maintaining our relationships in good faith and together reaping the benefits of our work. In August, 2011 the site was expanded to include information on the Eagle s Nest Project. As Project development continues, the website will be expanded to include aboriginal procurement and a jobs database program. 6.6 ADDITIONAL COMMUNICATION TOOLS Noront is open to ideas and proposals from First Nations and Aboriginal Communities on how information can be shared with the community as a whole. Noront has produced Project updates and a Project brochure, and will continue to do so as the EA process continues. Noront is supportive of getting Project information to all key constituent groups within potentially affected communities. NB /1-9 March 26, of 26 A-24 of 35

116 SECTION TRADITIONAL KNOWLEDGE PLAN 7.1 INTRODUCTION Both the provincial ToR and the federal EIS Guidelines for the Project set out what topics should be covered in the EA/EIS. These include several references to Aboriginal Traditional Knowledge (ATK). ATK can contribute to: The description of the existing environment Project siting and design Identification of issues Evaluation of potential effects Effectiveness of mitigation measures Follow-up monitoring programs Furthermore, the EA process shall: Promote and facilitate the contribution of traditional knowledge to the review process Describe efforts taken to obtain traditional knowledge where it is not available or not provided in a timely manner Describe where and how traditional knowledge is incorporated into the assessment, including in effects prediction, and determining mitigation measures The Traditional Knowledge Plan is anticipated to change as the Project progresses. The following plan outlines the specific ATK information Noront currently plans to collect, the methods that will be used to collect this ATK, and the approach that will be used to incorporate ATK into the EA and ongoing environmental planning for the Project. The ATK Plan is focused on the communities in the regional study areas, and recognizes that ATK information is the property of the community and must be treated accordingly. 7.2 INFORMATION REQUIRED The collection of ATK is an important component of the provincial EA process. Noront is collecting ATK to complement the other baseline studies being completed for the EA. ATK is required for the socio-economic and cultural resources studies and to complement the hydrology, aquatic and terrestrial biology studies. The following information requirements have been identified in the EIS Guidelines and will be fulfilled through literature reviews and ATK studies: Identification of the lands, waters and resources of specific value to Aboriginal people Identification of asserted and established Aboriginal and treaty rights Identification of traditional territories Identification of traditional activities currently carried out by Aboriginal groups Identification of current and historic usage of all waterways and water bodies affected by the Project Description of traditional dietary habits and dependence on country foods Identification of fish species of importance to Aboriginal groups NB /1-9 March 26, of 26 A-25 of 35

117 Description of harvesting of plants for medicinal purposes Identification of spiritual sites Evaluation of the ability of future generations of Aboriginal people to pursue traditional activities 7.3 METHODS OF DATA COLLECTION The two methods for information collection will be a literature review and group interviews. Additional interviews with historians engaged by First Nations bands may also be included if possible. A literature review will be conducted to identify existing ATK information that may be available. The review will focus on information about the Ojibway and Oji-Cree people and published ATK reports for planned or existing mining projects within northern Ontario. A series of group interviews will be conducted to cover various topics, including: Trapping and Hunting Fishing and Water Use Plant Harvesting Sacred and Spiritual Sites The methods and approach will be further refined as the Project progresses and through discussion with the Aboriginal communities involved. 7.4 INCORPORATION OF ATK Noront recognizes that there may be some sensitivity around the release of ATK information. In some instances, this information may inform the evaluation of alternatives or impact assessment, but not be specifically published (e.g., information regarding calving grounds, sensitive or rare species, etc., may not be released without the specific permission of the Aboriginal communities). Information received during interviews and literature review will be incorporated into the environmental assessment. A concordance table will be developed which will detail how the information has been incorporated and considered in each component of the environmental assessment. A secondary goal will be to identify Valued Ecosystem Components (VEC) through the collection of ATK. NB /1-9 March 26, of 26 A-26 of 35

118 SECTION ISSUE IDENTIFICATION AND TRACKING Noront is maintaining a record of consultation activities for the Project prior to and during the preparation of the EA. The consultation record keeps track of who was consulted, when, where and by what method. The consultation record also includes key issues and concerns that were identified by each stakeholder and Noront s response. As Noront moves towards completion of the EA process, it will provide a Draft Consultation Report to First Nations and Aboriginal Communities, summarizing key issues, concerns and interests raised and providing an opportunity to give input to the report and revise the issues or results as appropriate. Where broader issues are raised or issues raised in relation to government policy matters, Noront will document those so that government agencies are made aware of such issues and are better positioned to respond to such matters. Following formal community meetings, Noront will make available to First Nations and Aboriginal communities a summary of each meeting to ensure a shared understanding of issues and concerns. A preliminary issues list has been developed to help categorize communications with stakeholders and to better understand which topics are most important to stakeholders. The issues list has been organized into the following categories. Project Phases Project Details Project / EA Management Water Biology Geology Socio-Economic Aboriginal Interests Each stakeholder communication will be added to the database within two weeks of receipt by Noront. The communication will be linked to the appropriate issue from the existing issues list. The issues list will be modified as needed to reflect comments and feedback received throughout the consultation process. Stakeholders that have voiced a concern over an issue will receive a response from Noront that will contain information to help resolve or clarify the issue. All issues and concerns received will be logged in the record of consultation. Furthermore, Noront will document any comments/concerns that have been brought forward in the EA and note whether they have been addressed if any actions have been taken or if any actions are pending. NB /1-9 March 26, of 26 A-27 of 35

119 SECTION CONSIDERATION OF COMMENTS 9.1 INTRODUCTION Comments and concerns will be integrated into the EA report and will be used to inform the Project planning on an ongoing basis. The key consultation milestones provide a helpful framework for incorporation of comments by soliciting comments on draft documents before the final document is issued. Where comments cannot be incorporated, an explanation will be provided to the stakeholder, and added in the stakeholder database, for inclusion in the final Consultation Report. Noront will actively pursue information about Traditional Land Use and Traditional Ecological Knowledge throughout the consultation where the Project schedule allows, and as the willingness of Aboriginal community members is determined. Noront will also work towards the goal of responding to stakeholder comments and concerns within three weeks of receiving them. Comments will be addressed on an individual basis; however they will also be grouped into categories for efficiency and to allow the Noront team to identify trends. Addressing and responding to comments will depend on the nature of the comments and the manner in which they were received. It is anticipated that a variety of responses will be required, including but not limited to correcting typographical errors, providing detailed technical responses, clarifying technical jargon, modifying field programs, running additional modelling scenarios, modifying management plans, expanding stakeholder lists, and holding additional meetings. A comment-response table will be included in the final Consultation Report. The final comment-response table will reference specific sections in the EA report where the stakeholder comment was addressed, or where the answer to their questions can be found. The comment-response table will group comments by issue category for efficiency; however, comments and questions will be responded to and considered on an individual basis. 9.2 ISSUE RESOLUTION In some cases, comments may not be addressed to a stakeholder s satisfaction. An issue may come up where Noront and a group or individual cannot come to agreement on how to resolve a particular concern. In this case, Noront will work with the stakeholder to resolve the issue through a third party if needed, but will first attempt to resolve any issues through other means, such as focus meetings or working groups. NB /1-9 March 26, of 26 A-28 of 35

120 SECTION ONGOING CONSULTATION PLANNING The Consultation Plan will continue to be revised as the Project planning process continues. The Project is currently in the early stages of the EA and it is expected that plans will be modified, issues lists will be refined, and stakeholder lists will be further developed. Noront is committed to continual improvement and will take stakeholder comments into consideration throughout the EA process and beyond. Noront believes that stakeholder input will improve the EA process and the Project on the whole and is committed to meeting all consultation regulatory requirements for both the provincial and federal EA processes. NB /1-9 March 26, of 26 A-29 of 35

121 A-30 of 35

122 TABLE 4.1 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT CONSULTATION PLAN STAKEHOLDER ENGAGEMENT LIST - STAKEHOLDER, ABORIGINAL GROUPS AND GOVERNMENT REVIEW TEAM Federal Government Type Provincial Government Municipal Government Aboriginal Groups Non-Governmental Organization Government Review Team Member/Stakeholder Canadian Environmental Assessment Agency Fisheries and Oceans Canada Transport Canada Environment Canada Aboriginal Affairs and Northern Development Canada Health Canada Industry Canada (FedNor) Major Projects Management Office (MPMO) Ministry of the Environment Ministry of Natural Resources Ministry of Labour Ministry of Transportation Ministry of Northern Development and Mines Town of Pickle Lake Town of Ignace Municipality of Greenstone City of Thunder Bay Township of Ignace Unorganized Municipality of Savant Lake Attawapiskat First Nation Eabametoong First Nation Kasibonika First Nation Marten Falls First Nation Mishkeegogamang First Nation Neskantaga First Nation Nibinamik First Nation Weenusk First Nation Saugeen First Nation Webequie First Nation Métis Nation of Ontario Wildlands League (a chapter of CPAWS) Mining Watch Ecojustice Wildlife Conservation Society I:\1\02\00390\01\A\Report\Report 9, - ToR Consultation Plan\Tables\[Table 4.1.xls]Table 4.1 Print Mar/27/12 14:57: MAR'12 ISSUED WITH REPORT NB /1-9 JSP ALR SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D Page 1 of 1 A-31 of 35

123 TABLE 5.1 NORONT RESOURCES LTD. EAGLE'S NEST PROJECT CONSULTATION PLAN CONSULTATION PHASES, ACTIVITIES AND MATERIALS Print Mar/27/12 12:36:19 Consultation Phase Communication Methods Consultation Materials and Tools Phase 1 - Pre-Consultation Stakeholder Briefings One-on-one Meetings and Letters Phone Calls Meetings with Chief and Council Community Meetings and Presentations Project Description Project Brochures Project Presentations Phase 2 - Consultation on and during the preparation of the TOR and EA Stakeholder Briefings Community Meetings and Presentations and Letters Phone Calls Community Open Houses Meetings with Chief and Council Technical Workshops Participation in Tri - Lateral Meetings with Government or government led meetings Site Visits and Field Assessments Draft TOR Press Advertising Website Updates Feedback Forms Display Boards Project Brochures Phase 3 - Consultation and review of the findings presented in the EA Phase 4 - Post Approval/Ongoing Engagement Stakeholder Briefings Stakeholder Information Sessions Open Houses One-on-one meetings Participation in Tri - Lateral Meetings with Government or government led meetings Project Website Phone Calls and Letters Stakeholder Briefings Project Website and Letters Phone Calls Press Advertising Website Updates Feedback Forms Display Boards Project Brochures Press Advertising Website Updates Project Brochures I:\1\02\00390\01\A\Report\Report 9, - ToR Consultation Plan\Tables\[Table 5.1.xlsx]Table MAR'12 ISSUED WITH REPORT NB /1-9 JSP ALR SRA REV DATE DESCRIPTION PREP'D CHK'D APP'D Page 1 of 1 A-32 of 35

124 6,300,000 0 > ò" N 150, , , , , ,000 LEGEND: ROAD WINTER/SERVICE/RECREATION ROAD RAILWAY PROPOSED PERMANENT ROAD PROPOSED WINTER ROAD 20 KM BUFFER ABORIGINAL REGIONAL STUDY AREA (TREATY 9) FIRST NATIONS RESERVE Fort Severn PROVINCIAL PARK WATER ABORIGINAL REGIONAL STUDY AREA 6,150,000 Peawanuk 6,000,000 Treaty 9 Adhesions Kasabonika Kingfisher Lake Wunnumin Lake Webequie Attawapiskat 5,850,000 Nibinamik![ WEBEQUIE JUNCTION![ EAGLE'S NEST PROJECT Neskantaga Kashechewan Fort Albany NOTES: 1. BASE MAP: HER MAJESTY THE QUEEN IN RIGHTS OF CANADA DEPARTMENT OF NATURAL RESOURCES, LAND INFORMATION ONTARIO (LIO), (2009). ALL RIGHTS RESERVED. 2. COORDINATE GRID IS IN METRES. COORDINATE SYSTEM: NAD 1983 UTM ZONE 16N. 3. HISTORICAL INDIAN TREATIES OBTAINED FROM NATURAL RESOURCES CANADA, THE ATLAS OF CANADA (2011). SAVED: I:\1\02\00390\01\A\GIS\Figs\B191_r0.mxd; Mar 26, :02 PM; skozmick 5,700,000 Mishkeegogamang Red Lake Treaty 3 (1873) Savant Lake Sioux Lookout![ 0 26MAR'12 ISSUED WITH REPORT ALR ASM JSP SRA SAVANT LAKE CONCENTRATE TRANSFER FACILITY REV DATE DESCRIPTION DESIGNED DRAWN CHK'D APP'D Pickle Lake Marten Falls / Ogoki Post Fort Hope / Eabametoong Treaty 9 Nakina A-33 of 35 SCALE km NORONT RESOURCES LTD. EAGLE'S NEST PROJECT ABORIGINAL REGIONAL STUDY AREA P/A NO. REF NO. NB /1 9 FIGURE 4.1 REV 0

125 6,300,000 0 > ò" N 150, , , , , ,000 LEGEND: ROAD WINTER/SERVICE/RECREATION ROAD RAILWAY PROPOSED PERMANENT ROAD PROPOSED WINTER ROAD 20 KM BUFFER ABORIGINAL LOCAL STUDY AREA FIRST NATIONS RESERVE Fort Severn PROVINCIAL PARK WATER 6,150,000 Peawanuk 6,000,000 Kasabonika ABORIGINAL LOCAL STUDY AREA Kingfisher Lake Wunnumin Lake Webequie Attawapiskat 5,850,000 Nibinamik![ WEBEQUIE JUNCTION![ EAGLE'S NEST PROJECT Neskantaga Kashechewan Fort Albany NOTES: 1. BASE MAP: HER MAJESTY THE QUEEN IN RIGHTS OF CANADA DEPARTMENT OF NATURAL RESOURCES, LAND INFORMATION ONTARIO (LIO), (2009). ALL RIGHTS RESERVED. 2. COORDINATE GRID IS IN METRES. COORDINATE SYSTEM: NAD 1983 UTM ZONE 16N. SAVED: I:\1\02\00390\01\A\GIS\Figs\B192_r0.mxd; Mar 27, :56 PM; skozmick 5,700,000 Red Lake SAVANT LAKE CONCENTRATE TRANSFER FACILITY Sioux Lookout 0 26MAR'12 ISSUED WITH REPORT ALR ASM JSP SRA REV DATE DESCRIPTION DESIGNED DRAWN CHK'D APP'D Savant Lake![ Pickle Lake Mishkeegogamang Fort Hope / Eabametoong Aroland Nakina A-34 of 35 Marten Falls / Ogoki Post SCALE km NORONT RESOURCES LTD. EAGLE'S NEST PROJECT ABORIGINAL LOCAL STUDY AREA P/A NO. REF NO. NB /1 9 FIGURE 4.2 REV 0

126 6,300,000 0 > ò" N 150, , , , , ,000 LEGEND: ARCHAEOLOGICAL COMPLEXES (1630) # ARCHAEOLOGICAL COMPLEXES - CIRCA 1630 MAJOR LINGUISTIC FAMILIES!( ALGONQUIAN (1630)!( ALGONQUIAN (1740)!( ALGONQUIAN 1823) Fort Severn!( ATHAPAS(1823)!( METIS (1823)!( SIOUAN (1823) ROAD 6,150,000 ABORIGINAL REGIONAL STUDY AREA WINTER/SERVICE/RECREATION ROAD RAILWAY PROPOSED PERMANENT ROAD PROPOSED WINTER ROAD 20 KM BUFFER ABORIGINAL REGIONAL STUDY AREA (TREATY 9) FIRST NATIONS RESERVE Peawanuk # PROVINCIAL PARK WATER # # # 6,000,000 Treaty 9 Adhesions Kasabonika # Kingfisher Lake Wunnumin Lake Webequie Attawapiskat 5,850,000 Nibinamik![ WEBEQUIE JUNCTION![ EAGLE'S NEST PROJECT # # # # # # Neskantaga Kashechewan Fort Albany NOTES: 1. BASE MAP: HER MAJESTY THE QUEEN IN RIGHTS OF CANADA DEPARTMENT OF NATURAL RESOURCES, LAND INFORMATION ONTARIO (LIO), (2009). ALL RIGHTS RESERVED. 2. COORDINATE GRID IS IN METRES. COORDINATE SYSTEM: NAD 1983 UTM ZONE 16N. 3. HISTORICAL INDIAN TREATIES OBTAINED FROM NATURAL RESOURCES CANADA, THE ATLAS OF CANADA (2011). 4. HISTORICAL SETTLEMENTS AND ARCHAEOLOGICAL COMPLEXES OBTAINED FROM NATURAL RESOURCES CANADA, THE ATLAS OF CANADA (2011). SAVED: I:\1\02\00390\01\A\GIS\Figs\B193_r0.mxd; Mar 26, :11 PM; skozmick # # 5,700,000 Mishkeegogamang Red Lake # # # Treaty 3 (1873) Savant Lake Sioux Lookout![ ASM # 0 26MAR'12 ISSUED WITH REPORT ALR JSP SRA SAVANT LAKE CONCENTRATE TRANSFER FACILITY REV DATE DESCRIPTION DESIGNED DRAWN CHK'D APP'D Pickle Lake # # # # # # # # # # Fort Hope / Eabametoong Marten Falls / Ogoki Post Treaty 9 # Nakina # A-35 of 35 SCALE km NORONT RESOURCES LTD. EAGLE'S NEST PROJECT HISTORICAL SETTLEMENTS AND ARCHAEOLOGICAL COMPLEXES P/A NO. REF NO. NB /1 9 FIGURE 4.3 REV 0